Title VII, ADEA Retaliation Claims Dismissed

In Smith v. Centerlight Healthcare, Inc., 17-cv-2135, 2018 WL 3104086 (S.D.N.Y. June 21, 2018), the court, inter alia, dismissed plaintiff’s retaliation claims under Title VII of the Civil Rights Act of 1964 (Title VII) and the Age Discrimination in Employment Act (ADEA).

After summarizing the legal standard, the court applied the law to the facts, succinctly explaining:

Smith’s retaliation claims fail because her participation in the investigations and her internal complaints lack any causal nexus to her discharge, and the remaining aspects of the claims fail because Smith did not suffer an adverse employment action, they are time-barred, and/or they are purely speculative. Her participation in the investigations took place well outside the 300-day statute of the limitations, and she was not terminated from her employment until January 2016, rendering any inference of retaliatory motivation impossible to find on this record. And it is undisputed that … the sole decisionmaker in her termination[] did not learn about the internal complaints until plaintiff’s deposition, which defeats the possibility of retaliatory motivation.

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