NYC Human Rights Law Claims Barred by Collateral Estoppel [Karimian v. Time Equities]

In Karimian v. Time Equities, Inc., 2018 NY Slip Op 05583 (App. Div. 2nd Dept. Aug. 1, 2018), the court, inter alia, affirmed the dismissal of plaintiff’s claims of employment discrimination, hostile work environment, and retaliation.

The court explained that while “a cause of action asserted pursuant to NYCHRL must be analyzed independently from similar or identical causes of action asserted pursuant to Title VII and/or NYSHRL,” it was also the case that “where a prior factual determination rendered with regard to a Title VII or NYSHRL cause of action is determinative of a cause of action asserted pursuant to NYCHRL in a subsequent action, the NYCHRL cause of action may be barred pursuant to the doctrine of collateral estoppel.”

That, according to the court, is what happened here: “[T]the factual determinations made by the federal courts with regard to the causes of action alleging discrimination, retaliation, and hostile work environment under Title VII were determinative of the plaintiff’s identical claims asserted in this action pursuant to NYCHRL.”

Therefore, the court upheld the Supreme Court’s determination to dismiss those causes of action under the doctrine of collateral estoppel.