Title VII Discrimination, Hostile Work Environment, Retaliation Claims Dismissed on Collateral Estoppel Grounds Following NYSDHR Dismissal

In Featherstone v. Cornell University, 17-cv-565, 2017 WL 4736738 (NDNY Oct. 19, 2017), the court dismissed plaintiff’s Title VII discrimination, hostile work environment, and retaliation claims.

Plaintiff had initially asserted her claims at the New York State Division of Human Rights, which – after an investigation – found that there was no probable cause to support plaintiff’s claims. She challenged this determination by filing a CPLR Article 78 petition, which the New York Supreme Court dismissed. Plaintiff filed her complaint in the U.S. District Court for the Northern District of New York.

In finding that the doctrine of collateral estoppel barred plaintiff’s Title VII claims, the NDNY explained:

Plaintiff alleges retaliation, hostile work environment, and discrimination under Title VII. In her SDHR complaint, Plaintiff asserted the same claims based on the same underlying facts but pursuant to New York State Human Rights Law. SDHR found that there was no probable cause to support Plaintiff’s New York State Human Rights Law claims, and the state court affirmed that determination in the Article 78 proceeding. It is well settled that the standard for analyzing hostile work environment, retaliation, and discrimination claims is the same under Title VII and New York State Human Rights Law. See Chavis v. Wal-Mart Stores, Inc., No. 15-CV-4288, 2017 WL 3037536, *2 (S.D.N.Y. July 18, 2017). Therefore, it would be impossible to resolve the Title VII claims in Plaintiff’s favor in a manner that would be consistent with the state court’s Article 78 decision. See Barnes v. N.Y.S. Div. of Human Rights, No. 14-CV-2388, 2016 WL 110522, *5 (S.D.N.Y. Jan. 8, 2016) (“[F]ederal courts within this Circuit have repeatedly applied collateral estoppel in similar situations where, as here, (1) discrimination claims were made to the NYSDHR, (2) the NYSDHR issued a finding of no probable cause, (3) the plaintiff challenged the NYSDHR’s determination and procedures in state court and (4) the NYSDHR’s determination was affirmed by the New York courts”). Accordingly, Plaintiff’s Title VII claims are dismissed.

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