In Senderowitz v. Touro University, No. 160270/2025, 2026 WL 3027432 (N.Y. Sup. Ct. Sep. 28, 2026), the court denied defendant’s motion to dismiss plaintiff’s claim of retaliation under the New York State Human Rights Law.
From the decision:
To state a claim for retaliation under the NYSHRL, a plaintiff must allege that she engaged in protected activity, that the employer was aware of it, that she suffered a materially adverse action, and that a causal connection exists between the two (Forrest v Jewish Guild for the Blind, 3 NY3d 295, 312-313 [2004]). The NYCHRL applies a more liberal standard, requiring only that the employer took an action reasonably likely to deter a person from engaging in protected activity (Harrington v City of New York, 157 AD3d 582, 585 [2018]).
Here, plaintiff’s claim of retaliation is amply pleaded: she demonstrates that she had been employed by defendant for many years before she filed a complaint against HASC, that she was an employee in good standing and in fact was due to get a raise in the upcoming semester, that she was terminated by defendant very close in time to her complaint, and that the proffered reason for her termination appears to be false.
Plaintiff also pleads sufficient connections between defendant’s board members and people involved with HASC to raise the inference that defendant was aware of her complaint against HASC and that it terminated her employment in response thereto. At this stage of the litigation, plaintiff is entitled to explore these connections during discovery. None of the cases cited by defendant on this issue is apposite.
Accordingly, plaintiff’s claims will continue.