McKinney v. County of Dutchess

CourtCourt of Appeals for the Second Circuit
DecidedMay 27, 2025
Docket24-1195
StatusUnpublished

This text of McKinney v. County of Dutchess (McKinney v. County of Dutchess) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McKinney v. County of Dutchess, (2d Cir. 2025).

Opinion

24-1195-cv McKinney v. County of Dutchess

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 27th day of May, two thousand twenty-five.

PRESENT: GERARD E. LYNCH, MICHAEL H. PARK, BETH ROBINSON, Circuit Judges. _____________________________________

Stephanie McKinney,

Plaintiff-Appellant,

v. 24-1195

County of Dutchess,

Defendant-Appellee, Sheriff Adrian Anderson, in his personal and official capacity, State of New York, Dutchess County Sheriff Department,

Defendants. _____________________________________

FOR PLAINTIFF-APPELLANT: STEPHANIE MCKINNEY, pro se, Poughkeepsie, NY.

FOR DEFENDANT-APPELLEE: KIMBERLY HUNT LEE, Sokoloff Stern LLP, Poughkeepsie, NY.

Appeal from a judgment of the United States District Court for the Southern

District of New York (Nelson S. Román, Judge).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED,

ADJUDGED, AND DECREED that the judgment is AFFIRMED.

Stephanie McKinney, a former employee of the Dutchess County Sheriff’s

Department, sued Dutchess County under Title VII of the Civil Rights Act (“Title

VII”), the Americans with Disabilities Act (“ADA”), 42 U.S.C. § 1981, and 42 U.S.C.

§ 1983. The district court granted the County’s motion to dismiss McKinney’s

second amended complaint. McKinney v. Cnty. of Dutchess, No. 19-CV-03920, 2024

WL 1376499 at *3–12 (S.D.N.Y. Mar. 31, 2024). McKinney, now proceeding pro se,

2 appeals this dismissal. We assume the parties’ familiarity with the underlying

facts, the procedural history, and the issues on appeal.

“We review de novo the district court’s dismissal for failure to state a claim

under Rule 12(b)(6).” VIZIO, Inc. v. Klee, 886 F.3d 249, 255 (2d Cir. 2018).

I. Equal Protection

To state an equal protection claim under § 1983, a “plaintiff must allege that

similarly situated persons have been treated differently.” Gagliardi v. Vill. of

Pawling, 18 F.3d 188, 193 (2d Cir. 1994). “[B]ald allegations” that a municipality

showed preferential treatment to one group over another do not suffice. Id.

McKinney’s second amended complaint alleged that non-black employees

received more generous treatment than she. But most of the employees that the

complaint referenced committed some form of misconduct. Those employees thus

were not similarly situated to McKinney, who alleges she was ordered to return to

work too quickly after an injury.

McKinney’s complaint also alleged that some white officers were allowed

more time to recover from their injuries before returning to work. But McKinney

provides no detail as to the nature of the injuries sustained by those officers or the

length of their recovery periods. These allegations thus do not nudge McKinney’s

3 claim “across the line from conceivable to plausible.” Bell Atl. Corp. v. Twombly,

550 U.S. 544, 570 (2007).

II. Title VII

a. Racial Discrimination

To state a Title VII discrimination claim absent direct evidence of

discrimination, a plaintiff must plausibly allege that she “(1) is a member of a

protected class, (2) was qualified, (3) suffered an adverse employment action, and

(4) has at least minimal support for the proposition that the employer was

motivated by discriminatory intent.” Buon v. Spindler, 65 F.4th 64, 79 (2d Cir. 2023)

(cleaned up).

McKinney failed to plead facts showing a plausible inference of

discrimination. As with her equal protection claim, McKinney’s Title VII claim did

not describe how she was treated differently than similarly-situated white

employees. 1 Her complaint therefore did not create a plausible inference that any

alleged adverse employment actions were the result of racial discrimination.

1 See Feingold v. New York, 366 F.3d 138, 159 (2d Cir. 2004) (“Once action under color of state law is established, [a plaintiff’s] equal protection claim parallels his Title VII claim. The elements of one are generally the same as the elements of the other and the two must stand or fall together.” (footnote omitted)). 4 b. Hostile Work Environment

To survive a motion to dismiss on a hostile work environment claim under

Title VII, a plaintiff must allege conduct that “(1) is objectively severe or

pervasive—that is, creates an environment that a reasonable person would find

hostile or abusive; (2) creates an environment that the plaintiff subjectively

perceives as hostile or abusive; and (3) creates such an environment because of the

plaintiff’s [protected class].” Patane v. Clark, 508 F.3d 106, 113 (2d Cir. 2007)

(cleaned up). “[A] work environment’s hostility should be assessed based on the

totality of the circumstances.” Id. (quotation marks omitted). “Factors that a court

might consider in assessing the totality of the circumstances include: (1) the

frequency of the discriminatory conduct; (2) its severity; (3) whether it is

threatening and humiliating, or a mere offensive utterance; and (4) whether it

unreasonably interferes with an employee’s work performance.” Id. (quotation

marks omitted).

McKinney claims that she was aggressively questioned about her health

while she was on unpaid sick leave. But McKinney’s second amended complaint

provided no detail about how often this occurred, the content of these

conversations, or the duration of the conduct. So McKinney has not alleged facts

5 showing that any harassment was sufficiently severe and pervasive to state a claim

under Title VII.

c. Retaliation

“To state a claim for retaliation in violation of Title VII, a plaintiff must plead

facts that would tend to show that: (1) she participated in a protected activity

known to the defendant; (2) the defendant took an employment action

disadvantaging her; and (3) there exists a causal connection between the protected

activity and the adverse action.” Patane, 508 F.3d at 115.

McKinney alleges that she complained about discrimination and unfair

treatment of black officers to her supervisors. But her second amended complaint

did not allege to whom she complained, how often she did so, or when she made

these complaints. She also made only a bare assertion that her termination was

because of her complaints. McKinney thus failed to allege facts showing a

plausible connection between any protected activity and her termination.

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Related

Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Vivenzio v. City of Syracuse
611 F.3d 98 (Second Circuit, 2010)
Feingold v. New York
366 F.3d 138 (Second Circuit, 2004)
Patane v. Clark
508 F.3d 106 (Second Circuit, 2007)
Vizio, Inc. v. Klee
886 F.3d 249 (Second Circuit, 2018)
Buon v. Spindler
65 F.4th 64 (Second Circuit, 2023)

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McKinney v. County of Dutchess, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mckinney-v-county-of-dutchess-ca2-2025.