Court Dismisses NYCHRL Discrimination Claim Arising From Events Outside NYC

In McKinney v. Quayshanna Tanner of Set and Service Resource et al, 2019 WL 3067116 (SDNY July 12, 2019), the court, inter alia, dismissed plaintiff’s claims under the New York City Human Rights Law.

From the decision:

The Court must dismiss Plaintiff’s NYCHRL claims. The NYCHRL does not apply to discriminatory acts that occurred outside of New York City. Hardwick v. Auriemma, 116 A.D.3d 465, 466 (1st Dep’t 2014); Shah v. Wilco Sys, Inc., 27 A.D. 3d 169, 175 (1st Dep’t 2005); see also Hoffman v. Parade Publ’ns, 15 N.Y.3d 285, 291 (2010) (The NYCHRL’s “impact requirement is relatively simple for courts to apply and litigants to follow, leads to predictable results, and confines the protections of the NYCHRL to those who are meant to be protected – those who work in the city.”).

Plaintiff, a New York City resident, alleges that the discriminatory conduct occurred at a Loews hardware store in Yonkers, Westchester County, New York – outside of New York City. The Court therefore dismisses Plaintiff’s NYCHRL claims.