Moazzaz v. MetLife, Inc.
- James Oetken
- 1:19-cv-10531
- U.S. District Court · Southern District of New York
- 5
In Moazzaz v. MetLife, Judge Oetken granted reconsideration in part, granting Khalaf summary judgment before May 1, 2019, but denying it for later alleged pay violations.
Mona Moazzaz’s Equal Pay Act and New York Labor Law claims against Michel Khalaf were narrowed by time: claims based on alleged violations before May 1, 2019 received summary judgment for Khalaf, while claims based on alleged violations on or after that date remained unresolved after summary judgment was denied.
What happened
In Moazzaz v. MetLife, Inc., Mona Moazzaz asserted federal and New York equal-pay and discrimination claims against MetLife and several individuals. The court had previously denied Michel Khalaf summary judgment on the Equal Pay Act and New York Labor Law claims against him.
Khalaf asked the court to reconsider that decision, arguing that he was not an employer legally responsible for Moazzaz’s pay claims before he became MetLife’s chief executive officer. The court found no evidence that he controlled her work or participated in the relevant pay and promotion decisions before May 1, 2019, but found that a jury could decide he exercised such control after that date while she remained on MetLife’s payroll.
Judge Oetken granted reconsideration in part. He granted Khalaf summary judgment on the Equal Pay Act and New York Labor Law claims based on violations before May 1, 2019, but denied summary judgment on claims based on violations on or after that date. The court also denied Moazzaz’s renewed request to add a declaration to the record.
The detailed version
- Moazzaz v. MetLife, Inc. · No. 1:19-cv-10531
- James Oetken
- May 22, 2024
Background
Mona Moazzaz sued MetLife Group, Inc., Michel Khalaf, Steven Kandarian, Frans Hijkoop, Susan Podlogar, and Gary Hediger 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. In the earlier summary-judgment decision, the court granted Khalaf summary judgment on the state and city human-rights claims but denied him summary judgment on the Equal Pay Act and New York Labor Law claims.
Khalaf moved for reconsideration of the decision allowing those two equal-pay claims against him to continue. He argued that he could not be individually liable because he was not an “employer” under those statutes during the relevant period. Under the statutes, an individual may be an employer when the individual controls a company’s operations in a way related to the plaintiff’s employment, including workplace conditions, personnel decisions, or compensation. Personal involvement in the alleged violation is not required.
Court’s Analysis
The court decided to consider Khalaf’s argument even though Moazzaz contended that he had not raised it in his original summary-judgment papers. The court explained that it had addressed the employer issue itself in the prior summary-judgment opinion because neither side had correctly stated or applied the standard for individual liability. The court therefore exercised its discretion to consider the argument on reconsideration.
Khalaf became MetLife’s chief executive officer on May 1,
- The alleged unequal-pay violations occurred primarily in 2017 and
- Before becoming chief executive officer, Khalaf was MetLife’s Head of Europe, the Middle East, and America and worked outside the United States through late
- The court found that, before May 1, 2019, Moazzaz did not report to Khalaf directly or indirectly, Khalaf had no authority over the real-estate portfolio she oversaw, and the record did not show that he reviewed or evaluated her work or participated in decisions about her promotion or termination.
The court nevertheless found that Moazzaz remained on MetLife’s payroll through July 31, 2019, even though MetLife notified her on May 13, 2019, that her role was being eliminated. As a result, alleged underpayment continued during the first three months of Khalaf’s tenure as chief executive officer. The court concluded that a reasonable jury could find that Khalaf exercised the required control over Moazzaz’s employment during that period.
Rulings
The court granted Khalaf’s motion for reconsideration in part. Upon reconsideration, it granted Khalaf summary judgment on the Equal Pay Act and New York Labor Law claims based on violations before May 1, 2019, and denied summary judgment on those claims based on violations on or after May 1, 2019. The court also denied Moazzaz’s renewed request to submit an additional declaration. The clerk was directed to close Khalaf’s reconsideration motion.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.