Rys v. Davis

CourtCourt of Appeals for the Second Circuit
DecidedApril 2, 2026
Docket25-857
StatusUnpublished

This text of Rys v. Davis (Rys v. Davis) 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.

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Rys v. Davis, (2d Cir. 2026).

Opinion

25-857 Rys v. Davis

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.

1 At a stated term of the United States Court of Appeals for the Second Circuit, 2 held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the 3 City of New York, on the 2nd day of April, two thousand twenty-six. 4 5 PRESENT: John M. Walker, Jr., 6 Richard J. Sullivan, 7 Joseph F. Bianco, 8 Circuit Judges. 9 ----------------------------------------------------------------------- 10 SAMANTHA RYS,

11 Plaintiff-Appellant,

12 v. No. 25-857

13 SABRINA DAVIS, TANYA JOHNSON,

14 Defendants-Appellees. 15 ----------------------------------------------------------------------- 16 APPEARING FOR APPELLANT: MICHAEL H. SUSSMAN, Sussman & 17 Associates, Goshen, NY. 18

1 1 APPEARING FOR APPELLEES: GILLIAN BARNA (Barbara D. Underwood 2 and Judith N. Vale, on the brief), New York 3 State Office of the Attorney General, New 4 York, NY.

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

6 District of New York (Karas, J.).

7 UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED,

8 AND DECREED that the judgment of the district court is AFFIRMED.

9 For three months until her resignation in August 2021, Plaintiff-Appellant

10 Samantha Rys worked as a parole officer (“PO”) for the Brooklyn bureau of New

11 York’s Department of Corrections and Community Supervision (“DOCCS”). As a

12 PO at DOCCS, Rys was supervised by a senior parole officer, Tanya Johnson, who

13 in turn reported to the Brooklyn bureau chief, Sabrina Davis (together,

14 “Defendants-Appellees”). Johnson and Davis are Black women, while Rys is a

15 Caucasian woman.

16 In December 2022, Rys sued her supervisors under 42 U.S.C. § 1983, alleging

17 that Davis and Johnson created a hostile work environment and constructively

18 discharged Rys because of her race, in violation of the Equal Protection Clause of

19 the Fourteenth Amendment.

20 The district court granted summary judgment for Defendants-Appellees

21 after determining that Rys failed to meet the evidentiary burden on her hostile

22 work environment and constructive discharge claims. Rys appeals from the

23 district court’s grant of summary judgment. In this appeal, we consider whether

24 the district court erred in discrediting Rys’s declaration as a “sham affidavit” and

25 in granting summary judgment for Defendants-Appellees. We assume the parties’

2 1 familiarity with the underlying facts, procedural history, and arguments on

2 appeal, to which we refer only as necessary to explain our decision.

3 We review a district court’s grant of summary judgment de novo. Back v.

4 Hastings on Hudson Union Free Sch. Dist., 365 F.3d 107, 122 (2d Cir. 2004). Summary

5 judgment is appropriate when, viewing the evidence in the light most favorable to

6 the non-moving party, “there is no genuine issue as to any material fact” that could

7 lead to a judgment in the non-movant’s favor. Nabisco, Inc. v. Warner-Lambert Co.,

8 220 F.3d 43, 45 (2d Cir. 2000); Fed. R. Civ. P. 56(a).

9 We find that Rys failed to produce evidence that would create a genuine

10 dispute of material fact precluding summary judgment against her. In coming to

11 this conclusion, we note certain “unequivocal[,] inescapable, [and] unexplained”

12 contradictions between Rys’s deposition testimony and the declaration she

13 submitted after Defendants moved for summary judgment. In re Fosamax Prods.

14 Liab. Litig., 707 F.3d 189, 194 (2d Cir. 2013) (per curiam). We agree with the district

15 court’s observation that these contradictions resulted from Rys’s declaration being

16 a sham affidavit and thus we disregard them.

17 I. “Sham Affidavit”

18 Per the sham affidavit or “sham issue[] of fact” doctrine, “a party may not

19 create an issue of fact by submitting an affidavit in opposition to a summary

20 judgment motion that, by omission or addition, contradicts the affiant’s previous

21 deposition testimony.” Hayes v. N.Y.C. Dep’t of Corr., 84 F.3d 614, 619 (2d Cir.

22 1996). A sham issue of fact exists when the contradictions in a party’s affidavit,

23 compared to the party’s prior testimony, are “inescapable and unequivocal in

24 nature.” In re Fosamax Prods. Liab. Litig., 707 F.3d at 194. “[I]f there is a plausible

3 1 explanation for discrepancies in a party’s testimony,” however, “the court

2 considering a summary judgment motion should not disregard the later testimony

3 because an earlier account was ambiguous, confusing, or simply incomplete.”

4 Rojas v. Roman Cath. Diocese of Rochester, 660 F.3d 98, 106 (2d Cir. 2011) (per curiam)

5 (quoting Jeffreys v. City of New York, 426 F.3d 549, 555 n.2 (2d Cir. 2005)). We find

6 three contradictions between Rys’s prior testimony and her later declaration that

7 indicate that the later declaration is a “sham affidavit.”

8 First, Rys testified that while she did not know what other POs’ caseloads

9 looked like, Rys was assigned to “two precincts,” and this was somehow

10 “different” from others’ assignments. See Joint App’x at 147-48. 1 Her declaration

11 stated, in contrast, that she “was assigned to three police precincts” while “African

12 American parole officers were assigned one or two, most usually two.” Joint App’x

13 at 604 (Pl’s Decl. ¶ 7) (emphases added). To explain this contradiction, Rys refers

14 to general “remarks” made by her coworkers and a comment written by another

15 coworker on her farewell card stating, “I have nightmares about the 76, 78, and

16 84.” Joint App’x at 229, 605, 610-11. Rys alleges that this comment “refreshed [her]

17 recollection” that she was assigned to three, rather than two, precincts. Appellant

18 Brief at 30. Rys offers no evidence, however, to support her claim that her minority

1 “Q. . . . And did you – do you know what everybody else’s caseload looked like? A. I kept things in my lane. I don’t do that.” Joint App’x at 229 (Pl’s Dep. Tr. at 166:7-14). “Q. And is it your understanding that all the parole officers in the Brooklyn office had parolees within all five boroughs? A. Yes. My jurisdiction had two precincts though . . . which was different. Q. What do you mean by that? A. I don’t know. It just had two police [] precincts, so it was a different kind of community[,] I guess. Q.

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