Nafeesa Syeed v. Bloomberg

CourtNew York Court of Appeals
DecidedMarch 14, 2024
Docket20
StatusPublished

This text of Nafeesa Syeed v. Bloomberg (Nafeesa Syeed v. Bloomberg) is published on Counsel Stack Legal Research, covering New York Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Nafeesa Syeed v. Bloomberg, (N.Y. 2024).

Opinion

State of New York OPINION Court of Appeals This opinion is uncorrected and subject to revision before publication in the New York Reports.

No. 20 Nafeesa Syeed, Appellant, v. Bloomberg L.P., Respondent.

Niall MacGiollabhui, for appellant. Elise M. Bloom, for respondent. Cleland B. Welton II, for State of New York et al, amici curiae. Anti-Discrimination Center, Inc. et al., amici curiae.

SINGAS, J.:

The New York City Council and the New York State Legislature have enacted laws

banning discrimination, including employment discrimination, from within their

geographic boundaries. In response to a question certified by the United States Court of -1- -2- No. 20

Appeals for the Second Circuit, we hold that the New York City and New York State

Human Rights Laws each protect nonresidents who are not yet employed in the city or state

but who proactively sought an actual city- or state-based job opportunity.

I.

Plaintiff Nafeesa Syeed, a South Asian-American woman, filed this suit against

defendant Bloomberg L.P., asserting employment discrimination claims. She alleges that,

in 2014, she began working for defendant, a privately held company with global

headquarters in New York City. Defendant operates Bloomberg Media, a news

organization that employs reporters, editors, and producers throughout the world.

Plaintiff’s complaint alleged that she was subjected to discrimination on account of

her sex and race while working as a reporter in defendant’s Washington, D.C. bureau. In

2018, after plaintiff concluded that she could no longer advance her career in the

Washington, D.C. bureau, she “appl[ied] for various positions” at defendant’s New York

bureau, including “the New Economy Forum Editor position.” In addition, plaintiff

“affirmed her interest” to her Washington, D.C. team leader concerning an open United

Nations (U.N.) reporter position that was based in New York, and subsequently “inquired

multiple times” about that job. The U.N. vacancy ultimately was filled by a man who

allegedly had less practical experience than plaintiff and less formal education. After her

managing editor in Washington, D.C. told plaintiff that defendant decided not to convert

the U.N. job to a “ ‘diversity slot,’ ” she understood that she would only be considered for

promotions to positions identified as such. In June 2018, claiming that she was

constructively discharged, plaintiff informed her team leader and managing editor that she

-2- -3- No. 20

could no longer work for defendant because of the discrimination that she had encountered

and left defendant’s employ.

Two years later, plaintiff, then a California resident, commenced this class action in

New York State court. She asserted, among other causes of action, individual claims under

the State and City Human Rights Laws. Plaintiff maintained that defendant discriminated

against her on the basis of sex and race by denying her promotions.

After defendant removed the case to federal court, the United States District Court

for the Southern District of New York granted defendant’s motion to dismiss all of

plaintiff’s claims under both Human Rights Laws (see 568 F Supp 3d 314, 349 [SD NY

2021]). Concerning plaintiff’s failure to promote claims, the court, relying on our decision

in Hoffman v Parade Publs. (15 NY3d 285 [2010]), held that plaintiff could not show that

defendant’s conduct impacted her in New York State or City (see 568 F Supp 3d at 330).

The court read Hoffman and its progeny to hold that the Human Rights Laws are limited to

people who live or work in New York (see id. at 333). Because plaintiff alleged neither

and her claims instead rested “solely on her allegations that . . . she applied for, and was

denied, certain New York-based positions,” the court held that plaintiff’s allegations failed

to state a claim under the Human Rights Laws (id. at 330). The court acknowledged,

however, that other cases from the Southern District had reached the opposite conclusion

in analogous circumstances (see id. at 330-331; see e.g. Chau v Donovan, 357 F Supp 3d

276, 283-284 [SD NY 2019]; Anderson v HotelsAB, LLC, 2015 WL 5008771, *3-4, 2015

US Dist LEXIS 111820, *10-12 [SD NY, Aug. 24, 2015, No. 15CV712 (LTS-JLC)]).

-3- -4- No. 20

The Second Circuit reserved decision on plaintiff’s appeal and certified the

following question to this Court:

“Whether a nonresident plaintiff not yet employed in New York City or State satisfies the impact requirement of the New York City Human Rights Law or the New York State Human Rights Law if the plaintiff pleads and later proves that an employer deprived the plaintiff of a New York City- or State- based job opportunity on discriminatory grounds” (58 F4th 64, 71 [2d Cir 2023]).

The court concluded that Hoffman “was silent as to whether, in discriminatory failure-to-

hire or failure-to-promote cases, a nonresident plaintiff” would be “unable to assert

sufficient personal impact in New York City or State” (id. at 68). The Second Circuit

explained that “[c]ertain portions of Hoffman seem to imply that nonresidents can satisfy

the . . . impact requirement only if they currently work in New York City or State” (id.).

However, the Second Circuit noted that Hoffman left open the possibility that its impact

test might be satisfied by “those who would work in New York City or State absent

discrimination” (id. at 69). Given the policy implications involved and the lack of

controlling authority, the Second Circuit determined that certification was appropriate.

We accepted the certified question (see 39 NY3d 1061 [2023]), and answer it in the

affirmative.

II.

The State and City Human Rights Laws proscribe employment discrimination based

on, among other grounds, race and either sex or gender (see Executive Law § 296 [1] [a];

Administrative Code of City of NY § 8-107 [1] [a] [2]). Both statutes have provisions

directing that they be liberally construed to accomplish the remedial purposes that they

-4- -5- No. 20

serve (see Executive Law § 300; Administrative Code § 8-130 [a]). “Exceptions to and

exemptions from” both statutes “shall be construed narrowly in order to maximize

deterrence of discriminatory conduct” (Executive Law § 300; Administrative Code

§ 8-130 [b]). Courts must construe the Human Rights Laws “broadly in favor of

discrimination plaintiffs, to the extent that such a construction is reasonably possible”

(Albunio v City of New York, 16 NY3d 472, 477-478 [2011]; see Makinen v City of New

York, 30 NY3d 81, 88 [2017]). Applying this mandate to interpret these laws broadly, we

turn to the question presented.

Hoffman established an “impact” test for nonresidents seeking to assert claims under

the State and City Human Rights Laws. There, the plaintiff was a Georgia resident who

worked in Atlanta for the defendant, a company headquartered in New York City.

Claiming that his termination violated the Human Rights Laws, the plaintiff commenced

an age discrimination action in New York where the decision to fire him was made. We

concluded that “nonresidents of the city and state must plead and prove that the alleged

discriminatory conduct had an impact within those respective boundaries” (15 NY3d at

289). We emphasized that “the impact requirement does not exclude all nonresidents from

[the] protection” of the Human Rights Laws (id. at 290). Instead, the impact test “expands”

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Related

Hoffman v. Parade Publications
933 N.E.2d 744 (New York Court of Appeals, 2010)
Albunio v. City of New York
947 N.E.2d 135 (New York Court of Appeals, 2011)

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