Pizarro v. Euros El Tina Restaurant Lounge and Billiards Corp.

CourtDistrict Court, S.D. New York
DecidedFebruary 27, 2024
Docket1:20-cv-05783
StatusUnknown

This text of Pizarro v. Euros El Tina Restaurant Lounge and Billiards Corp. (Pizarro v. Euros El Tina Restaurant Lounge and Billiards Corp.) 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
Pizarro v. Euros El Tina Restaurant Lounge and Billiards Corp., (S.D.N.Y. 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ee re a a ee eee x MARIA JOSE PIZARRO, Plaintiff, : ORDER DENYING _avainst- > DEFENDANTS’ POST TRIAL . : MOTIONS, AND GRANTING EUROS EL TINA RESTAURANT LOUNGE > PLAINTIFFS FEES MOTION AND BILLIARDS CORP. and SANTIAGO : QUEZADA, : 20 Civ. 5783 (AIKH) Defendants.

ee ee ee eee ee x ALVIN K. HELLERSTEIN, U.S.D.J.: Plaintiff Maria Pizarro sued her employer, Defendant Euros El Tina Restaurant Lounge and Billiards Corp., and her manager Defendant Santiago Quezada, under Title VIL of the Civil Rights Act of 1964 and New York state and city law for Quezada’s repeated sexual harassments, creating a hostile work environment. After a four-day trial in October 2023, Plaintiff won a verdict against Defendants of $1,725,000 in compensatory damages ($1,000,000 against Quezada and an additional $725,000 against Euros El Tina), and $1,000,000 in punitive damages ($625,000 against Quezada and $375,000 against Euros El Tina). Judgment against Defendants in these amounts was entered on February 23, 2024. See ECF No. 194, [assume familiarity with the case background and trial transcript. Defendants move for judgment dismissing the case as a matter of law under Fed. R. Civ. P. 50(b), or for a new trial under Fed. R. Civ. P. 59(a). Plaintiff moves for attorneys’ fees and costs. For the reasons that follow, Defendants’ motion is denied, and Plaintiff's motions are granted,

I. Defendants’ Motion for Judgment as a Matter of Law or New Trial A, Sufficiency of the Evidence Defendants argue that they are entitled to judgment as a matter of law on Plaintiff's New York City Human Rights Law (NYCHRL) claim because Plaintiff failed to offer proof of how a male comparator was treated in support of her claim that she was treated “less well” because of her gender. A court may grant judgment as a matter of law against a party if it finds “that a reasonable jury would not have a legally sufficient evidentiary basis to find for the party on that issue.” Fed, R. Civ. P. 50(b). The motion should be granted only if “viewed in the light most favorable to the nonmoving party, ‘the evidence is such that, without weighing the credibility of the witnesses or otherwise considering the weight of evidence, there can be but one conclusion as to the verdict that reasonable men could have reached.’” Samuels v, Air Transport Local 504, 992 F.2d 12, 14 (2d Cir. 1993) (citation omitted) The evidence of sexual harassments and hostile work environment were overwhelming. Plaintiffs testimony, Jose Eladio Castro’s testimony, and Cristian Dilone’s testimony amply support the jury’s verdict. No employee is required to experience such harassments, neither male nor female. There is no requirement of a male comparator to support a finding of gender discrimination, or “less well” treatment, under NYCHRL. Defendants cite to no statute ot case imposing such a requirement, nor did they request that the jury be so instructed. Defendants do not contest the verdict under the more difficult standards of Title VIL

ot New York state law. See Mihalik v. Credit Agricole Cheuvreux North Am., Inc., F.3d 102, 109 (2d Cir 2013) (explaining that NYCHRL standard is lower than federal and state law standards for hostile work environment claims); Pryor v. Jaffe & Asher, LLP, 992 F, Supp. 2d 252, 261 (S.D.N.Y. 2014) The issue was properly decided by the jury.

B. Jury Charge Chailenges Defendants assert that they are entitled to a new trial because of two issues related to the jury charge: 1) the Defendant company’s affirmative defense, and 2) the absence of a specific mention of the statute of limitations in the verdict form, Inadequate jury instructions may constitute grounds for a new trial, provided the

errors ate “prejudicial in light of the charge as a whole.” Lore vy, City of Syracuse, 670 F.3d 127, 156 (2d Cir. 2012). An erroneous jury instruction “misleads the jury as to the correct legal standard or does not adequately inform the jury on the law.” /d. An error ina jury instruction is not prejudicial “when [the court is] persuaded it did not influence the jury's verdict.” Townsend

v. Benjamin Enters., Inc., 679 F.3d 41, 56 Qd Cir, 2012). “An omission, or an incomplete instruction, is less likely to be prejudicial than a misstatement of the law.” Lore, 670 F.3d at 156. A new trial is not warranted if the instructions “read as a whole, presented the issues to the jury in a fair and evenhanded manner.” Jd. i, Affirmative Defense Charge Defendant Euros El Tina sought, and I included in my jury charge, an affirmative defense that employers can assert against Title VII liability. I charged that an employer may avoid liability if both of two elements are met: “First, the employer must have exercised reasonable care to prevent and correct promptly any sexually harassing behavior, and Second, that the employee unreasonably failed to take advantage of any preventive or corrective opportunities provided by the employer to avoid harm.” Trial Tr. at 243:15-20, Defendant

argues that I should have added “or to avoid harm otherwise." See Burlington Indus. Inc. v. Ellerth, 524 U.S. 742, 765 (1998). My charge had no impact on the trial’s outcome. Quezada was plaintiffs boss and the principal of Defendant Euros El Tina. Plaintiff had no others to whom she could complain. And the evidence was clear that she was in no position to “avoid harm otherwise,”

other than to quit her job, Defendants bear the burden of proof on this issue, and point to no evidence that would tend to support cither element of their affirmative defense. Again, the jury properly delivered a verdict against both defendants. The verdict was not “seriously erroneous

ot a miscarriage of justice.” Farrior v. Waterford Bd. of Educ., 277 ¥.3d 633, 634-35 (2d Cir. 2002). ik. Statute of Limitations Charge Defendants seek a new trial on the grounds that the verdict sheet should have added a specific question about the statute of limitations. However, the jury was instructed, without objection, on the statute of limitations. My charge to the jury stated: Because of the statute of limitations, you may consider only acts that took place after May 17, 2019, with one important exception. If the conduct before and after May 17, 2019, was sufficiently similar in nature, frequency, and severity that it can be considered sufficiently related as to be part of a hostile work environment, you can conclude that. However, if the conduct spans across people, departments, and large time intervals without having harassing conduct, then you could find the acts to be insufficiently related. Trial Tr. at 242:20-243:7. Defense counsel did not object to the verdict sheet or to the charge, and did not repeat the request they made at a pre-trial conference for a specific verdict on the statute of limitations. See Sequa Corp. v. GBJ Corp., 156 F.3d 136, 144 (2d Cir. 1998). Defendants’ effort to impeach the verdict is without merit. C. Remittitur Defendants request remittitur on the grounds that the compensatory damages amounts, divided into $1,000,000 against Defendant Quezada and $725,000 against Defendant Euros El Tina, were grossly excessive, Their papers do not expressly challenge punitive damages.

i.

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Bluebook (online)
Pizarro v. Euros El Tina Restaurant Lounge and Billiards Corp., Counsel Stack Legal Research, https://law.counselstack.com/opinion/pizarro-v-euros-el-tina-restaurant-lounge-and-billiards-corp-nysd-2024.