2d Circuit Affirms Summary Judgment for Equinox on Age Discrimination Claims

In Adams v. Equinox Holdings, Inc., 2024 WL 1787108 (2d Cir. Apr. 25, 2024) the U.S. Court of Appeals for the Second Circuit affirmed the lower court’s award of summary judgment dismissing plaintiff’s claims of discrimination asserted under the Age discrimination in Employment Act and the New York City Human Rights Law.

From the decision:

We review an award of summary judgment de novo.” Rivera v. Rochester Genesee Reg’l Transp. Auth., 743 F.3d 11, 19 (2d Cir. 2014). “Summary judgment is appropriate only where, construing all the evidence in the light most favorable to the non-movant and drawing all reasonable inferences in that party’s favor, there is no genuine issue as to any material fact and … the movant is entitled to judgment as a matter of law.” Id. (quotation marks omitted). “A genuine issue exists for summary judgment purposes where the evidence, viewed in the light most favorable to the nonmoving party, is such that a reasonable jury could decide in that party’s favor.” Guilbert v. Gardner, 480 F.3d 140, 145 (2d Cir. 2007) (quotation marks omitted).
We affirm for substantially the reasons given by the district court.

Adams fails to present any evidence of age-based conduct by Equinox that would give rise to an inference of discrimination. Equinox, on the other hand, presents a legitimate, non-discriminatory, and non-retaliatory reason for terminating Adams—namely, she violated company policy by threatening a co-worker at the workplace. Thus, Adams’s claims of discrimination, hostile environment, and retaliation under the ADEA and the NYCHRL fail, and so do her aiding and abetting discrimination claims. See Williams v. N.Y.C. Hous. Auth., 61 F.4th 55, 68 (2d Cir. 2023) (“[A]n aiding and abetting claim is only viable when an underlying violation has taken place.”).

This is yet another decision illustrating that in order to make out a claim under the anti-discrimination laws, a plaintiff must present evidence connecting their membership in a protected class (here, age) to the alleged wrongful conduct by the employer.

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