Polito v. City of New York

CourtDistrict Court, E.D. New York
DecidedMay 29, 2020
Docket1:15-cv-02301
StatusUnknown

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

Bluebook
Polito v. City of New York, (E.D.N.Y. 2020).

Opinion

UNITED STATES DISTRICT COURT NOT FOR PUBLICATION EASTERN DISTRICT OF NEW YORK

JULIANNE POLITO,

Plaintiff,

– against – MEMORANDUM & ORDER

THE CITY OF NEW YORK, et al., 15-cv-02301 (ERK) (RML)

Defendants.

KORMAN, J.:

On September 26, 2016, Julianne Polito filed her Second Amended Complaint against Defendants, alleging an array of federal and state law claims arising out of the termination of her at-will agreement with Hand in Hand, Inc., an agency that assigns early intervention providers to students with developmental disabilities. 2d Am. Compl, ECF No. 55. On December 21, 2017, I dismissed all of Polito’s claims against except for one—her claim for tortious interference with contract. Mem. & Order 6, ECF No. 71. When I declined to dismiss that claim on the pleadings, I observed that the “thrust of Polito’s complaint” was that she “alleges that the defendants threatened her employer ‘with economic ruin if [it] did not terminate Polito’s contract.’” Id. at 9 (citing 2d Amend. Compl. ¶¶ 42, 58). I suggested that if proven, this allegation could support a viable tortious interference claim. Id. at 9–10 (citing Lurie v. New Amsterdam Casualty Co., 270 N.Y. 379, 381 (1936) (upholding tortious-interference verdict where insurer threatened to withhold payment to car- accident victim unless victim fired his at-will attorney)); see Taboola, Inc. v. Ezoic Inc., 2020 WL 1900496, at *8 (S.D.N.Y. Apr. 17, 2020) (“Where the means employed to induce the breach are ‘wrongful,’ however, the valid contract prong of

a tortious interference claim may be satisfied by an at-will contract.”). At the same time, I explained that “discovery may well reveal that the defendants’ actions were a justified response to a parent’s valid complaint rather than what Polito describes.”

Mem. & Order 10. After such discovery took place, Defendants moved for summary judgment.

BACKGROUND

In 2006, Polito began working with Hand in Hand as a state-appointed early intervention case worker on an at-will basis. On December 24, 2014, a parent emailed Hand in Hand service coordinator Francia Despradel saying that she had

seen a NY Post article reporting that while Polito was a teacher at MS 344 Academy of Collaborative Education, she had thrown a book at a student and made derogatory remarks towards that same student. Defs.’ 56.1 Stmt. ¶¶ 17–19, ECF No. 172. The parent stated it was “totally unacceptable” that the agency would “refer someone like

[Polito] to [her] family,” and added that she intended to speak with “early intervention” (it is unclear if she meant the City or State). Id. at ¶ 17. On December 31, 2013, Ms. Despradel forwarded the parent’s complaint to

an assistant director at the City’s Bureau of Early Intervention. Id. at ¶ 21. The email was then forwarded internally to Patricia Pate, Director of Provider Oversight, who shared the parent’s message with Nora Puffett, the Bureau’s Director of Administration and Data for Early Intervention. Id. Pate testified that shortly

thereafter, she called Margaret Adeigbo at the New York State Health Department to discuss how to proceed. Pate Dep. Tr. 29:3–5, 30:8–20, ECF No. 171-9. Pate explained the parent’s complaint to the Health Department, and said she intended to

discuss the matter with Hand in Hand. Id. The Health Department “agreed with [the Bureau’s] plan to tell Hand in Hand.” Id. at 30:17–20. On January 15, 2014, Pate and Puffet spoke on the phone with Dr. Leah Lax, Hand in Hand’s Education Director, and Beth Statfield, Hand in Hand’s Chief

Financial Officer. Defs.’ 56.1 Stmt. ¶ 33. Dr. Lax testified that Defendants did not tell Hand in Hand that they had to terminate Polito’s contract or convey that Hand in Hand’s ongoing business was conditioned on terminating their relationship with

Polito. Defs.’ 56.1 Stmt. ¶¶ 38–39, 41–42; Lax Dep. Tr. 116:14–19, 116:24–117:5, ECF No. 171-10. Likewise, Statfield testified that Defendants did not tell Hand in Hand to terminate Polito’s agreement, and when she was asked if she was told that Hand in Hand would not receive any more cases from the City Department of Health

and Mental Hygiene if they did not terminate Polito, she replied “not that I recall.” Defs.’ 56.1 Stmt. ¶ 39; Statfield Dep. Tr. 148:7–10, 148:15–20, ECF No. 175-13. The only recommendation Dr. Lax and Statfield recalled from the phone call was

Pate’s recommendation that they reach out to the State Department of Health. Defs.’ 56.1 Stmt. ¶ 37; Pate Dep. Tr. 44:13–14, 45:21–24; Statfield Dep. Tr. 149:4–10. Indeed, Dr. Lax testified that following that phone call, she spoke to Margaret Adeigbo at the Department of Health regarding Polito. Lax Dep. Tr. 69:10–25, ECF

No. 175-14. One week after the conference call, Pate emailed Lax and Statfield to check whether Hand in Hand had an update regarding Polito. In the brief exchange that

followed, Statfield indicated that Hand in Hand would no longer be working with Polito. Defs.’ 56.1 Stmt. ¶¶ 44–47. In response, Pate replied, “thank you,” which she testified she said out of “basic politeness.” Pate Dep. Tr. 59:16–21.

STANDARD OF REVIEW Summary judgment is appropriate if “the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). Viewing the facts in the light most favorable to

the party opposing the motion, Matsushitsa Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 587–88 (1986), a genuine dispute of material fact exists “if the evidence is such that a reasonable jury could return a verdict for the nonmoving

party,” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). “Conclusory allegations, conjecture, and speculation, however, are insufficient to create a genuine issue of fact.” Kerzer v. Kingly Mfg., 156 F.3d 396, 400 (2d Cir. 1998). DISCUSSION A. Applicable Law Under New York law, the elements of tortious interference with contract are (1) “the existence of a valid contract between the plaintiff and a third party”; (2) the

“defendant’s knowledge of the contract”; (3) the “defendant's intentional procurement of the third-party's breach of the contract without justification”; (4) “actual breach of the contract”; and (5) “damages resulting therefrom.” Kirch v.

Liberty Media Corp., 449 F.3d 388, 401 (2d Cir. 2006). The Second Circuit has held that to prove the third element, “procurement of the third-party’s breach of the contract without justification,” an at-will employee must “establish that [the] ‘third

party used wrongful means to effect the termination such as fraud, misrepresentation, or threats, that the means used violated a duty owed by the defendant to the plaintiff, or that the defendant acted with malice.’” Albert v. Loksen, 239 F.3d 256, 274 (quoting Cohen v. Davis, 926 F. Supp. 399, 403 (S.D.N.Y. 1996)). The critical

question is whether, based on the January 15, 2014 phone call between Pate, Puffett, Lax, and Statfield, Defendants procured Polito’s firing using “wrongful means.” Id. at 274.

B.

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Related

Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Cohen v. Davis
926 F. Supp. 399 (S.D. New York, 1996)
Lurie v. New Amsterdam Casualty Co.
1 N.E.2d 472 (New York Court of Appeals, 1936)
Davis v. New York
316 F.3d 93 (Second Circuit, 2002)
Kirch v. Liberty Media Corp.
449 F.3d 388 (Second Circuit, 2006)

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