BENDETSEN v. UNITED AIRLINES, INC.

CourtDistrict Court, D. New Jersey
DecidedMarch 26, 2025
Docket2:23-cv-01553
StatusUnknown

This text of BENDETSEN v. UNITED AIRLINES, INC. (BENDETSEN v. UNITED AIRLINES, INC.) is published on Counsel Stack Legal Research, covering District Court, D. New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
BENDETSEN v. UNITED AIRLINES, INC., (D.N.J. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

CHERYL BENDETSEN, BARBARA

MAROVICH, JANICE CURRAN, FRED Civil Action No. 23-01553 (JXN)(MAH) ESTAÑO, TAMMARA COOK, and

MARYSOL CHAPARRO,

OPINION Plaintiffs,

v.

UNITED AIRLINES, INC.,

Defendant.

NEALS, District Judge This matter comes before the Court by way of Defendant United Airlines, Inc.’s (“United” or “Defendant”) motion to dismiss Plaintiffs Cheryl Bendetsen, Barbara Marovich, Janice Curran, Fred Estaño, Tammara Cook, and Marysol Chaparro’s (collectively “Plaintiffs”) Amended Complaint pursuant to Federal Rule of Civil Procedure 12(b)(1) and 12(b)(6). (ECF No. 43.) Plaintiffs opposed the motion (ECF No. 44), and United replied in further support (ECF No. 45). Jurisdiction is proper pursuant to 28 U.S.C. § 1331. Venue is proper pursuant to 28 U.S.C. § 1391. The Court has carefully reviewed the parties' submissions and decides this matter without oral argument pursuant to Federal Rule of Civil Procedure 78 and Local Civil Rule 78.1. For the reasons set forth below, United’s motion to dismiss is GRANTED. I. FACTUAL AND PROCEDURAL BACKGROUND1 Plaintiffs bring this employment action against United for age discrimination and retaliation under the Age Discrimination in Employment Act, 29 U.S.C. §§ 623(a) and (d),

1 When reviewing a motion to dismiss, a court accepts as true all well-pleaded facts in the complaint. Fowler v. UPMC Shadyside, 578 F.3d 203, 210 (3d Cir. 2009). (“ADEA”) (Count I), and the New Jersey Law Against Discrimination, N.J.S.A. 10:5-12 (“NJLAD”) (Count II). (See Amended Complaint (“Am. Compl.”), ECF No. 32.) United is a global commercial airline that operates out of multiple domestic hubs, including but not limited to Newark Liberty International Airport (“EWR”). (Am. Compl. ¶ 13.)

Prior to the involuntary terminations of employment challenged here, Plaintiffs served as Flight Attendants/Pursers for United based out of EWR. (Id. ¶ 5.) Plaintiffs performed their Flight Attendant duties satisfactorily, received numerous awards and accolades in connection with job performance, and none had received discipline resulting in a loss of pay or warning that would result in termination on further offense. (Id. ¶ 6-12.) The Purser job itself is a position of leadership from the standpoint of safety and crew duties. (Id. ¶ 14.) Plaintiffs were all over 40 years old when they were terminated from their employment with United in May 2021. (Id.) A. The March 6, 2021 WhatsApp Chat Incident Plaintiffs’ termination from employment stemmed from their participation in a two-hour private WhatsApp chat among EWR-based United Pursers that occurred on March 6, 2021 (the

“March 6 Chat”). (Id. ¶ 15.) The March 6 Chat was open to around fifty (50) EWR-based United Pursers. (Id.) During the March 6 Chat, Plaintiffs made several statements about Kristof Hering (“Hering”), a junior Flight Attendant based out of United’s Dulles hub, who had documented crewmembers for allegedly violating United’s COVID-19 mask requirement. (Id. ¶ 19.) Plaintiffs claim the March 6 Chat focused on their concerns regarding the “actions taken against older, senior flight attendants,” because of photos Hering posted on social media of crewmembers with their faces “clearly visible,” and their concern that Hering would target them “amid rumors that [he] was going to transfer to EWR.” (Id.) Plaintiffs further allege an “unknown source took selective screenshots” of the March 6 Chat and provided it to United. (Id. ¶ 20.) The comments made by Plaintiffs during the March 6 Chat include the following:2 This guy is part of the 5500 was given an emergency xfer [sic] from DC as he has had 6 senior people fired He takes photos of [FA’s] and photo shops them and turns them in to the company spread the word he is trouble. The Mole … if he takes my picture, his ass will be in front of a judge … He looks like the Joker without makeup I just heard he has taken COLA[]! Wait till he get[s] our warm welcome Remind me please as to what happens to snitches in prison? … Hmmm. Does he park in the NY/NJ parking lot? … Watch out, there are cameras in the lot. … Okay. Need to know more about what he has done…. this is not good enough gassip [sic]. I am bored right now. Spain’s programg [sic] tonight is a bit boring… … My friend from iAd confirms his unsavory credentials. How can I send a photo from my text to this app? A more realistic photo of him in September 2020. … [In response to pictures of Hering being posted in the chat]: He was probably Tinkerbell in Disney. … We got him! Be careful He is not a ‘Red Herring’……...

2 The Court finds that the WhatsApp chat referred to in Plaintiffs’ Amended Complaint is central to Plaintiffs’ claims, and accordingly, will consider the copy of the WhatsApp Chat provided by United (ECF No. 20-5) in deciding the motion to dismiss without converting the motion to a motion for summary judgment. In re Burlington Coat Factory Sec. Litig., 114 F.3d 1410, 1426 (3d Cir. 1997). So what’s the story about the 6 seniors being fired… that’s alot [sic] of power.. anything about that story? We need to make his life miserable And the thing about his mother…that is just effing sick! This is the kind of thing that needs to get leaked to on [sic] of those airline bloggers!” That might shut him up AND the company if its leaked UA approves of it … (March 6 Chat (redacted), ECF No. 20-5 at *1-11.)3 B. United’s Investigation and Termination of Plaintiffs’ Employment After receiving the screenshots of the March 6 Chat, United began an investigation into Plaintiffs’ conduct. (Id. ¶¶ 20, 38-39.) Following its investigation, United terminated Plaintiffs for bullying, harassment, and retaliation in violation of United’s Working Together Guidelines (“Guidelines”), governing United’s employment of flight attendants and other personnel, which are referred to in the Collective Bargaining Agreement (“CBA”) between United and Plaintiffs’ union, the Association of Flight Attendants (“AFA”). (Id. ¶ 21; see also ECF No. 20-4.) Plaintiffs allege that United discriminated against them based on age during the investigation and termination process. (Am. Compl. ¶ 38.) Plaintiffs allege that 1) the extreme punishment of summary dismissal of plaintiffs for minor, questionable “offenses” is way out of line with far lesser penalties exacted against young flight attendants for truly serious offenses; and 2) United has a highly reticulated progressive disciplinary system, with built[-]in due process protections, that was bypassed in the case of the older flight attendants.

(Id. ¶ 2.) Specifically, Plaintiffs assert that the charges against them—bullying, harassment, and retaliation- by their nature, “require some type of confrontation, direct or indirect, between the accused and the target of the alleged nefarious activity.” (Id. ¶ 35.) Plaintiffs contend, however, that because they did not know Hering or communicate with him directly, United’s

3 Pin-cites preceded by an asterisk (*) refer to the pagination atop the CM/ECF header.

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