Richmond v. Sorensen

CourtDistrict Court, S.D. New York
DecidedJanuary 7, 2025
Docket7:22-cv-10075
StatusUnknown

This text of Richmond v. Sorensen (Richmond v. Sorensen) 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
Richmond v. Sorensen, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ---------------------------------------------------------------x JULIA RICHMOND, : Plaintiff, : : OPINION AND ORDER v. : : 22 CV 10075 (VB) ALAN J. SORENSEN, : Defendant. : ---------------------------------------------------------------x

Briccetti, J.: Plaintiff Julia Richmond brings this action pursuant to 42 U.S.C. § 1983 alleging defendant Alan J. Sorensen violated her Fourteenth Amendment right as a public employee to be free from gender discrimination. Now pending is defendant’s motion for summary judgment. (Doc. #35). For the reasons set forth below, the motion is GRANTED. The Court has subject matter jurisdiction pursuant to 28 U.S.C. § 1331. BACKGROUND The parties have submitted briefs, statements of material fact pursuant to Local Civil Rule 56.1, and declarations with exhibits. These submissions reflect the following factual background. I. Plaintiff’s Employment From October 2016 until the termination of her employment in December 2021, plaintiff served as Deputy Commissioner of the Orange County (the “County”) Department of Planning and Development (the “Department”). She was appointed to the position by the Department’s former Commissioner. In March 2020, defendant was appointed as the Department’s new Commissioner. Plaintiff and defendant previously worked together for two years in the early 2000s when both were employed by Sullivan County. In 2001, defendant, who was then the Sullivan County Commissioner of Planning, hired plaintiff as his Deputy Commissioner of Planning. They worked together until defendant left his position in 2003. Plaintiff contends that during her

employment at the Sullivan County, defendant was “intimidated” by plaintiff and prevented plaintiff from fulfilling her duties as Deputy Commissioner. (Doc. #40-1 (“Pl. Depo.”) at 51– 52). After joining the Department as Deputy Commissioner in 2016, plaintiff served as the Project Manager on the West Central Transportation and Land Use Study (the “West Central Study”). The West Central Study focused on several transportation corridors and key intersections in the County, and the Department retained an outside consultant to assist with the project. (Doc. #37 ¶ 24). In addition, plaintiff oversaw Orange County’s Motor Vehicle Emission Simulator (“MOVES”) study, which required the County to prepare an analysis of air pollutants, greenhouse gases, and other air toxins emitted from mobile sources. Due to the

technical nature of the study, plaintiff was involved in retaining consultants to conduct the requisite analysis. (Id. at ¶ 31). Plaintiff’s responsibilities also included the duties of the Director of the Orange County Transportation Council (the “OCTC”). The OCTC is the Metropolitan Planning Organization (the “MPO”) for Orange County, a statutorily created organization that advises on transportation projects that use federal funds. Department employees staff the OCTC on behalf of the County. The OCTC is tasked with developing the annual United Planning Work Program (the “UPWP”) detailing the County’s plans for the expenditure of federal funds. (Doc. #37 ¶¶ 16–17). Although there is no formal appointment procedure for the role of Director of the OCTC, plaintiff chaired the OCTC meetings. (Pl. Depo. at 99). In late 2021, defendant developed concerns about plaintiff’s job performance. Defendant contends he learned of project redundancies in the West Central Study—including development

plans for an intersection that was already the subject of another transportation project—and invoicing inconsistencies. (Doc. #37 ¶¶ 26–30; Doc. #36-7 at 71). In addition, defendant asserts plaintiff directed a contractor to begin work on a MOVES analysis before a contract was in place. (Doc. #37 ¶¶ 31–32). Finally, in October 2021, defendant informed plaintiff he would take over the role of Director of the OCTC. Despite this change, defendant asserts plaintiff continued to identify herself as the OCTC Director in relevant contracts. (Id. at ¶¶ 33–35). Plaintiff disputes the accuracy of defendant’s claims about her job performance. According to plaintiff, any inconsistencies in the West Central Study were premature and would eventually have been resolved. (Pl. Depo. at 78). As for the MOVES contract, plaintiff did not recall if she authorized a contractor to begin working on the MOVES analysis before a contract

was confirmed, and even if she had, she contends such approval would have been consistent with Department practice. (Doc. #42 ¶ 20). As for the OCTC documents, plaintiff asserts she retained her title because she was still the main point of contact for the OCTC. (Doc. #46 at 8– 9). On November 4, 2021, defendant wrote a memorandum to file regarding several deficiencies in plaintiff’s performance, particularly relating to the MOVES analysis and the West Central Study. (Doc. #36-8). Plaintiff acknowledges she and defendant discussed these issues “on different occasions” and in “miscellaneous conversations,” but disputes that defendant ever told her to improve upon these issues or risk impacting her job. (Pl. Depo. at 64–65, 97). Plaintiff otherwise contends she was not aware of defendant’s concerns about her job performance. II. Plaintiff’s Termination and Replacement On December 8, 2021, plaintiff met with defendant and a human resources (“HR”)

representative. Defendant informed plaintiff, an at-will employee, that he had “decided to go in another direction” with the Deputy Commissioner position and handed plaintiff a letter terminating her employment. (Pl. Depo. at 105). The letter did not provide any reasons for the termination. (Doc. #36-5). When plaintiff asked why she was being terminated, neither defendant nor the HR representative responded. In the weeks following her termination, plaintiff inquired with different HR employees regarding the reasons for her termination but received no response. In November 2021, prior to plaintiff’s termination, another employee in the Department, Ashlee Long, resigned to take a position in another county. Long was a Planner in the Department but also performed administrative duties for the OCTC, including completing the

OCTC Agenda, preparing the annual UPWP, and coordinating program changes. Long had assumed these responsibilities after the former Deputy Commissioner of Planning, John Czamanske, who had previously performed these functions, retired in 2016. (Doc. #37 at ¶ 15). Czamanske had also previously served as the Director of the OCTC. After Long resigned, defendant attempted to hire Long as a consultant to train another employee in the Department, Lauren Bennett, to assume some of Long’s responsibilities, particularly those relating to the UPWP. Long declined. Instead, defendant appointed Czamanske as Deputy Commissioner of Planning. (Doc. #37 at ¶¶ 19–22). In this role, Czamanske was primarily tasked with training Bennett on the UPWP duties and was also assigned some of plaintiff’s and Long’s responsibilities. Czamanske served as Deputy Commissioner from December 2021 to March 2022 and received a higher salary than plaintiff had received in the role. (Doc. #36-14). Eventually, a woman was hired permanently to fill the Deputy Commissioner position. (Doc. #37 at ¶¶ 39–42).

III. Evidence of Discriminatory Behavior Prior to her termination, plaintiff had not complained of discriminatory treatment by defendant or anyone else in the Department. There is no evidence defendant made disparaging remarks towards plaintiff. (Pl. Depo. at 127–28). For the duration of her employment at the County, plaintiff testified her relationship with defendant was “pleasant.” (Id. at 62–63).

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Richmond v. Sorensen, Counsel Stack Legal Research, https://law.counselstack.com/opinion/richmond-v-sorensen-nysd-2025.