Moazzaz v. MetLife, Inc.

Background

Mona Moazzaz sued MetLife, Inc. and individual defendants Michel Khalaf, Steven Kandarian, Frans Hijkoop, Susan Podlogar, and Gary Hediger. She asserted claims under the federal Equal Pay Act, New York’s equal-pay law, the New York State Human Rights Law, and the New York City Human Rights Law. Her claims concerned alleged unequal pay, failure to promote, a hostile work environment, and termination because of sex.

MetLife used a Global Grading System to assign numerical grades to jobs. Moazzaz argued that her expanded responsibilities supported a higher grade and that human-resources officials had discretion to influence the grading process. She also presented evidence about comments and conduct that she said reflected gender bias. MetLife contended that its grading system, complaints about Moazzaz’s management style, and a corporate reorganization supplied legitimate, nondiscriminatory explanations for its decisions.

Pay-discrimination claims

The court denied summary judgment on Moazzaz’s pay claims against MetLife under the Equal Pay Act, New York Labor Law § 194(1), the New York State Human Rights Law, and the New York City Human Rights Law. Summary judgment is appropriate only when no reasonable jury could find for the opposing party based on a genuine dispute about an important fact.

For the federal Equal Pay Act claim, the court found that MetLife did not dispute paying Moazzaz less than certain male comparators and appeared not to dispute that the jobs were performed under similar working conditions. Although MetLife presented evidence that one comparator’s position differed substantially from Moazzaz’s, the court found insufficient evidence to eliminate her claim involving other comparators: Chris Smith, Steve Weinreb, Toby Brown, and Ed Spehar. A jury could reasonably find that Moazzaz’s job and one or more of those positions involved substantially equal responsibility.

The court also found factual disputes about whether MetLife’s Global Grading System was a legitimate factor other than sex or instead a pretext for discrimination. The record included evidence that the system was intended to assess job responsibilities, that human-resources employees had discretion to influence its results, and that Hediger made a remark from which a jury could infer gender bias. The court applied substantially the same reasoning to Moazzaz’s New York State and New York City pay claims.

Hostile-work-environment claims

The court granted summary judgment to MetLife on Moazzaz’s hostile-work-environment claims under both the New York State Human Rights Law and the New York City Human Rights Law. The court identified one potentially gender-based 2014 remark by Hediger, involving the word “bitch,” but found that the remark was outside the applicable limitations period.

The court found insufficient evidence of other timely gender-based harassment or of a continuing pattern connecting the 2014 remark to later conduct. It also concluded that the evidence did not support a finding that the timely conduct was severe or pervasive, or that gender played a role in the other alleged treatment. The court therefore granted summary judgment on both hostile-work-environment claims.

Failure-to-promote claims

The court denied summary judgment on Moazzaz’s failure-to-promote claims under the New York State Human Rights Law and the New York City Human Rights Law. Moazzaz was denied a promotion to the Executive Vice President level in 2017, even though her predecessor and successor as Head of Global Real Estate were Executive Vice Presidents. The court relied on the same evidence concerning the grading system, human-resources discretion, possible gender bias, and comparisons with male employees that supported the pay claims. It found triable factual issues about discrimination and pretext.

Termination claims

The court granted summary judgment to MetLife on Moazzaz’s termination claims under the New York State Human Rights Law and the New York City Human Rights Law. MetLife presented evidence that James O’Donnell eliminated Moazzaz’s position during a corporate realignment, that some of her responsibilities had already moved outside the relevant organization, and that MetLife did not refill her former position because the job no longer existed.

The court found that Moazzaz had not produced evidence from which a reasonable jury could conclude that these explanations were a cover for discrimination. Her arguments that her duties were redistributed to male employees and that another male chief of staff was retained did not create a sufficient factual dispute about pretext. The court concluded that discrimination played no role in the termination as a matter of law.

Individual defendants

The court denied summary judgment for Khalaf, Kandarian, and Podlogar on Moazzaz’s Equal Pay Act and New York Labor Law equal-pay claims. It found factual issues about whether Khalaf and Kandarian exercised operational control over Moazzaz’s employment as MetLife CEOs and whether Podlogar exercised such control through her authority over personnel and compensation.

The court granted summary judgment to all individual defendants on the hostile-work-environment and termination claims because it had granted summary judgment to MetLife on those claims.

For the New York State and New York City pay and failure-to-promote claims, the court granted summary judgment to Khalaf, Kandarian, and Hijkoop. It found insufficient evidence that Khalaf or Hijkoop actually participated in the alleged discriminatory conduct during the relevant period, and it found insufficient evidence that Kandarian participated in or aided discriminatory conduct.

The court denied summary judgment to Podlogar and Hediger on those New York State and New York City claims. It found evidence from which a jury could conclude that Podlogar participated in reviewing Moazzaz’s job grading and that Hediger participated through his role in the Global Grading System process.

Disposition

The court granted in part and denied in part Defendants’ motion for summary judgment. MetLife’s motion was granted on the New York State and New York City hostile-work-environment and discriminatory-termination claims and denied in all other respects. The individual defendants’ motions were granted on those hostile-work-environment and termination claims; the motions of Kandarian, Khalaf, and Podlogar were denied on the Equal Pay Act and New York Labor Law claims; the motions of Hijkoop, Kandarian, and Khalaf were granted on the New York State and New York City pay and failure-to-promote claims; and the motions of Hediger and Podlogar were denied on those claims.