Benedith v. White Plains Hospital

CourtDistrict Court, S.D. New York
DecidedOctober 4, 2021
Docket7:21-cv-08077
StatusUnknown

This text of Benedith v. White Plains Hospital (Benedith v. White Plains Hospital) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Benedith v. White Plains Hospital, (S.D.N.Y. 2021).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK . PETER C, BENEDITH, Plaintiff, 21-CV-8077 (CS) -against- ORDER TO AMEND WHITE PLAINS HOSPITAL, Defendant. CATHY SEIBEL, United States District Judge:

Plaintiff, appearing pro se, paid the filing fee to bring this action under Title VII of the Civil Rights Act of 1964 (Title VII). He also brings state-law discrimination claims under the New York State Human Rights Law (NYSHRL). Plaintiff, who identifies himself as “African,” alleges that Defendant White Plains Hospital declined to hire him as a physician because of his. race, color, and national origin. For the reasons set forth below, the Court grants Plaintiffleave to file an amended complaint within sixty days of the date of this order. STANDARD OF REVIEW The Court has the authority to dismiss a complaint, even when the plaintiff has paid the filing fee, if it determines that the action is frivolous, Fitzgerald v. First E. Seventh Tenants Corp., 221 F.3d 362, 363-64 (2d Cir. 2000) (per curiam) (citing Pillay v. INS, 45 F.3d 14, 16-17 (2d Cir. 1995) (per curiam) (holding that Court of Appeals has inherent authority to dismiss frivolous appeal)), that it fails to state a claim, Wachtler v. County of Herkimer, 35 F.3d 77, 82 . (2d Cir, 1994), or that the Court lacks subject matter jurisdiction, Rukrgas AG vy. Marathon Oil Co., 526 U.S. 574, 583 (1999). The Court is obliged, however, to construe pro se pleadings liberally, Harris v. Mills, 572 F.3d 66, 72 (2d Cir. 2009), and interpret them to raise the “strongest

{claims] that they suggest,” Triestman v. Fed. Bureau of Prisons, 470 F.3d 471, 474-75 (2d Cir. 2006) (internal quotation marks and citations omitted) (emphasis in original). The exact degree of solicitude that should be afforded to a pro se litigant in any given case depends upon a variety of factors, however, including the procedural context.and relevant characteristics of the particular litigant. Tracy v. Freshwater, 623 F.3d 90 (2d Cir. 2010). frequent pro se litigant may be charged with knowledge of particular legal requirements. See Sledge v. Kooi, 564 F.3d 105, 109-110 (2d Cir. 2009) (discussing circumstances where frequent pro se litigant may be charged with knowledge of particular legal requirements), BACKGROUND

Plaintiff alleges that White Plains Hospital declined to hire him, and that “the decision not to hire was based on discrimination based on [his] race and national origin.” (ECF 1 { IV.) Plaintiff asserts that the failure to hire him “contradicts a stated policy noted on [Defendant’s] website,” but Plaintiff does not provide any other facts in support of his discrimination claim. Plaintiff acknowledges that he has not exhausted his administrative remedies with the Equal Employment Opportunity Commission.’ Plaintiff seeks money damages. DISCUSSION A. Plaintiff fails to state a claim Title VII provides that “[i]t shall be an unlawful employment practice for an . employer . . . to fail or refuse to hire or to discharge any individual, or otherwise to discrimimate against any individual with respect to his compensation, terms, conditions, or privileges of

1 Rven where a right-to-sue letter is required, such as for a Title VII claim, administrative exhaustion is a claim-processing rule that must be raised as an affirmative defense, rather than a. jurisdictional requirement. See Fort Bend Cnty, Texas v. Davis, 139 8. Ct. 1843, 1846 (2019) (“Title VII’s charge-filing instruction is not jurisdictional.”); Hardaway v. Hartford Pub. Works Dep t, 879 F.3d 486, 491 (2d Cir. 2018).

employment, because of such individual’s race, color, religion, sex or national origin.” 42 U.S.C. § 2000e-2(a), The complaint could also be construed as asserting a claim under 42 U.S.C. § 1981, which prohibits discrimination in the making and enforcing of contracts, including employment contracts, “on account of [a person’s] race, ancestry, or ethnic characteristics.” Zemsky v. City of New York, 821 F.2d 148, 150 (2d Cir. 1987). These antidiscrimination provisions prohibit employers from mistreating an individual because of the individual’s protected characteristics, Patane v. Clark, 508 F.3d 106, 112 (2d Cir. 2007), or retaliating against an employee who has opposed any practice made unlawful by those statutes, see Crawford v. Metro. Govt, 555 U.S. 271, 276 (2009) (holding that conduct is protected when it “confront[s],” “resist[s],” or “withstand[s]” unlawful actions). Mistreatment at work that occurs for a reason other than an employee’s protected characteristic or opposition to unlawful conduct is not actionable under these federal antidiscrimination statutes. See Chukwuka

v, City of New York, 513 F. App’x 34, 36 (2d Cir. 2013) (quoting Brown v. Henderson, 257 ¥.3d 246, 252 (2d Cir. 2001)). At the pleading stage in an employment discrimination action, “a plaintiff must plausibly allege that (1) the employer took adverse employment action against him, and (2) his race, color, religion, sex, or national origin was a motivating factor in the employment decision.” Vega v. Hempstead Union Free Sch. Dist., 801 F.3d 72, 86 (2d Cir. 2015). The plaintiff “may do so by alleging facts that directly show discrimination or facts that indirectly show discrimination by giving rise to a plausible inference of discrimination.” /d. at 87. Plaintiff’s allegations are insufficient to state a claim under Title VII or § 1981. Plaintiff alleges that Defendant discriminated against him by not hiring him, but he does not allege facts suggesting that his race, color, or national origin played any role in Defendant’s decision not to

hire him, Rather, his only allegation is that the failure to hire him “contradicts” a policy statement on Defendant’s website.” Plaintiff makes a legal conclusion that Defendant discriminated against him but does not show a causal connection between Plaintiffs race, color, or national origin and any adverse employment action taken by Defendant. In short, nothing in the complaint suggests that one of Plaintiff’s protected characteristics motivated Defendant not to hire him. Plaintiff seems to rely on the fallacy that because he is a member of a protected class, it is plausible that any adverse employment action directed at him was because of his membership in that class, but it is well settled that such reasoning does not suffice to state a claim. See Watkins v. First Student, Inc., No. 17-CV-1519, 2018 WL 1135480, at *15 G.D.N.Y.

Feb, 28, 2018) (collecting cases). B.

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Related

Ruhrgas Ag v. Marathon Oil Co.
526 U.S. 574 (Supreme Court, 1999)
Chavis v. Chappius
618 F.3d 162 (Second Circuit, 2010)
Tracy v. Freshwater
623 F.3d 90 (Second Circuit, 2010)
Zemsky v. City of New York
821 F.2d 148 (Second Circuit, 1987)
Salahuddin v. Cuomo
861 F.2d 40 (Second Circuit, 1988)
Hill v. Curcione
657 F.3d 116 (Second Circuit, 2011)
Wachtler v. County Of Herkimer
35 F.3d 77 (Second Circuit, 1994)
Chukwuka v. City of New York
513 F. App'x 34 (Second Circuit, 2013)
Sledge v. Kooi
564 F.3d 105 (Second Circuit, 2009)
Patane v. Clark
508 F.3d 106 (Second Circuit, 2007)
Harris v. Mills
572 F.3d 66 (Second Circuit, 2009)
Hardaway v. Hartford Public Works Department
879 F.3d 486 (Second Circuit, 2018)
Dolan v. Connolly
794 F.3d 290 (Second Circuit, 2015)
Vega v. Hempstead Union Free School District
801 F.3d 72 (Second Circuit, 2015)

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Bluebook (online)
Benedith v. White Plains Hospital, Counsel Stack Legal Research, https://law.counselstack.com/opinion/benedith-v-white-plains-hospital-nysd-2021.