Horoschak v. Sirius XM Radio, Inc.

District Court, S.D. New York·Decided July 24, 2025·No. 1:24-cv-08177·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ---------------------------------------------------------------------- X : DAVID HOROSCHAK, et al., : : Plaintiff, : : 24-CV-8177 (JMF) -v- : : MEMORANDUM OPINION SIRIUS XM RADIO, INC., : AND ORDER : Defendant. : : ---------------------------------------------------------------------- X JESSE M. FURMAN, United States District Judge: Plaintiffs David Horoschak, Michael Harris, and Mills Staylor — all former employees of Defendant Sirius XM Radio LLC (“Sirius XM”) — bring this action, on behalf of themselves and others similarly situated, alleging unlawful age discrimination under the Age Discrimination in Employment Act (“ADEA”), 29 U.S.C. § 621 et seq., the New York State Human Rights Law (“NYSHRL”), N.Y. Exec. Law § 290 et seq., and the New York City Human Rights Law (“NYCHRL”), N.Y.C. Admin. Code § 8-101 et seq. ECF No. 1 (“Compl.”), ¶¶ 1, 14.1 The merits of their individual claims are not at issue here. Instead, the Court is called upon to decide whether to grant Plaintiffs’ motion for conditional certification of a collective action. See ECF No. 19. To warrant conditional certification, Plaintiffs must show that they and other putative collective action members were victims of a common policy or plan that violated the law. For the reasons that follow, the Court concludes that Plaintiffs fail to make that showing and denies their motion.

1 Plaintiffs incorrectly name Defendant as Sirius XM Radio, Inc. See ECF No. 22 (“Def.’s Opp’n”), at 7. BACKGROUND The following background facts are drawn from Plaintiffs’ Complaint, which is presumed to be true for purposes of this motion, see, e.g., She Jian Guo v. Tommy’s Sushi Inc., No. 14-CV- 3946 (PAE), 2014 WL 5314822, at *1 n.1 (S.D.N.Y. Oct. 16, 2014), and from the materials

submitted by Plaintiffs in support of their motion. Horoschak, Harris, and Staylor were each employed by Sirius XM for over a decade and were each over forty years old when, in 2024, they were terminated. Compl. ¶¶ 18-29. According to Sirius XM, the three were terminated as part of a February 2024 reduction in force (“RIF”) that eliminated approximately 160 roles — or about 3% of its workforce. See ECF No. 20 (“Pls.’ Mem.”), at 3; see also ECF No. 20-1 (“Ex. 1”). Plaintiffs contend, however, that the RIF was a pretext for age discrimination. Compl. ¶ 30. More specifically, they allege that, beginning in 2022, Sirius XM’s “new leadership orchestrated a significant and entirely illegal shift in company culture, prioritizing the recruitment of younger employees based on their age.” Id. ¶ 15. As evidence of that shift, they point to a May 2022 presentation, during which Sirius

XM’s Chief Technology Officer (“CTO”) Joe Inzerillo “explicitly stated that the company intended to recruit younger employees in order to align the workforce with a younger target customer base.” Id. ¶ 16. Plaintiffs allege that, “[i]n the months that followed, [Sirius XM] engaged in a series of discriminatory actions against older employees, including Plaintiffs, culminating in termination of employment” as part of the February 2024 RIF. Id. ¶ 17; see Ex. 1. The Complaint alleges, for example, that two of the three named Plaintiffs received unjustified negative performance reviews; two of the three were “marginalized”; and all three were replaced by younger, less experienced, and less qualified employees. Compl. ¶¶ 20, 24, 27, 28, 30. Plaintiffs now move for conditional certification of a collective action, with the collective defined in one instance as “all” Sirius XM “employees over forty (40) years of age whose employment separated (either because of layoff, discharge, or potential constructive discharge (i.e. resignation)) since February 12, 2024,” ECF No. 19, at 1 (emphasis added), and in another

as “employees . . . over the age of forty (40) who have been terminated or otherwise separated from employment since 2022,” Pls.’ Mem. 2 (emphasis added). In support of their motion, Plaintiffs provided only one exhibit: the email that announced the February 2024 RIF. Ex. 1. They filed no declarations, affidavits, or other evidence in support of their motion. LEGAL STANDARDS The enforcement provision of the ADEA, 29 U.S.C. § 626(b), incorporates the enforcement provisions of the Fair Labor Standards Act (“FLSA”), id. §§ 201, et seq., which allow workers to bring a so-called collective action by suing on behalf of both themselves and “other employees similarly situated,” id. § 216(b). It is well established that “district courts have discretion, in appropriate cases, to implement § 216(b) by facilitating notice to potential

plaintiffs of the pendency of the action and of their opportunity to opt-in as represented plaintiffs.” Myers v. Hertz Corp., 624 F.3d 537, 554 (2d Cir. 2010) (quoting Hoffman-La Roche Inc. v. Sperling, 493 U.S. 165, 169 (1989)) (cleaned up). In deciding whether to certify a collective action, district courts in the Second Circuit generally follow a “two-step method.” Id. at 555. At the first step, called conditional certification, courts ask “whether similarly situated plaintiffs exist,” Ramos v. Platt, No. 13-CV- 8957 (GHW), 2014 WL 3639194, at *3 (S.D.N.Y. July 23, 2014), and — in an exercise of discretion — determine whether to send notice to the group of potential opt-in plaintiffs, Myers, 624 F.3d at 555. At the second step, which follows the close of discovery, courts determine “whether the plaintiffs who have opted in are in fact ‘similarly situated’ to the named plaintiffs,” and, if the records reveal that they are not, courts can de-certify the collective. Id.; Korenblum v. Citigroup, Inc., 195 F. Supp. 3d 475, 480 (S.D.N.Y. 2016). Plaintiffs’ motion concerns the first step. To warrant conditional certification, Plaintiffs

need to meet only the “low” evidentiary burden of making a “modest factual showing that they and potential opt-in plaintiffs together were victims of a common policy or plan that violated the law.” Myers, 624 F.3d at 555 (internal quotation marks omitted); Korenblum, 195 F. Supp. 3d at 480.2 The “key element” of this required showing is the existence and implementation of “a shared unlawful policy.” Argudo v. Parea Grp. LLC, No. 18-CV-0678 (JMF), 2019 WL 4640058, at *3 (S.D.N.Y. Sept. 24, 2019); see Korenblum, 195 F. Supp. 3d at 479. Members of the proposed collective need not be “identical in every possible respect,” but they must be “similarly situated with respect to the allegedly unlawful policy or practice.” Korenblum, 195 F. Supp. 3d at 479; see also Jackson v. New York Tel. Co., 163 F.R.D. 429, 432 (S.D.N.Y. 1995) (“[P]laintiffs are only required to demonstrate a factual nexus that supports a finding that

potential plaintiffs were subjected to a common discriminatory scheme.”). To carry their burden at this preliminary stage, Plaintiffs may rely on their “own pleadings, affidavits, and declarations.” Chen v. Matsu Fusion Rest. Inc., No. 19-CV-11895 (JMF), 2020 WL 13841319, at *1 (S.D.N.Y. Nov. 16, 2020) (alterations omitted). But Plaintiffs’ burden cannot “be satisfied simply by unsupported assertions,” Myers, 624 F.3d at 555 (internal quotation marks omitted), or “conclusory allegations,” Sanchez v. JMP Ventures, L.L.C., No. 13-

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Horoschak v. Sirius XM Radio, Inc., (S.D.N.Y. 2025).

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