Eisenhauer v. Culinary Institute of America

Background

Anita Eisenhauer, a female professor at the Culinary Institute of America, sued the Culinary Institute under the federal Equal Pay Act and New York Labor Law § 194(1), alleging sex-based pay discrimination. After discovery, the parties filed cross-motions for summary judgment, which asks whether the record shows that one party is entitled to judgment without a trial.

In November 2021, the Court granted summary judgment to the Culinary Institute on both claims. The Second Circuit affirmed the ruling on the Equal Pay Act claim but vacated the ruling on the New York Labor Law claim. It held that the two claims could not be evaluated under the same legal standard because New York’s amended statute requires the employer’s stated reason for a pay difference to be job-related. The Second Circuit sent the case back for the Court to decide whether to hear the remaining state-law claim and, if so, to reconsider that claim.

Positions on Remand

On remand, Eisenhauer argued that the Court should decline to exercise supplemental jurisdiction—the federal court’s authority to hear a related state-law claim. The Culinary Institute argued that the Court should exercise that authority. The Court concluded that it had supplemental jurisdiction because the federal and state claims arose from the same alleged pay disparity, but it also concluded that it could decline to exercise that jurisdiction because the federal claim had been resolved.

Court’s Analysis

The Court considered judicial economy, convenience, fairness, and respect for state courts. It found that these considerations favored declining jurisdiction. Although the case had been pending since 2019 and discovery had been completed, the judge handling the case on remand had no greater familiarity with the facts and legal issues than a state-court judge would have. Only one state-law claim against one defendant remained, and any additional discovery would likely be limited to the statute’s job-relatedness requirement.

The Court also concluded that declining jurisdiction would not unfairly prejudice the Culinary Institute. The parties largely agreed on the facts and would need little additional preparation before filing further summary-judgment motions in state court. Finally, the Court emphasized that New York courts had not definitively interpreted the job-relatedness requirement in § 194(1), particularly in a case involving a collective bargaining agreement. Respect for state courts therefore strongly favored allowing a state court to address that unresolved state-law issue.

Disposition

The Court declined to exercise supplemental jurisdiction. Judge Victoria Reznik dismissed Eisenhauer’s New York Labor Law § 194(1) claim without prejudice, directed the Clerk to terminate pending motions, and closed the case. The Court did not decide the merits of that remaining state-law claim in this opinion.