Smart v. USA Lab. for Hire, Inc.

CourtCourt of Appeals for the Second Circuit
DecidedApril 28, 2025
Docket24-1791
StatusUnpublished

This text of Smart v. USA Lab. for Hire, Inc. (Smart v. USA Lab. for Hire, Inc.) 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.

Bluebook
Smart v. USA Lab. for Hire, Inc., (2d Cir. 2025).

Opinion

24-1791 Smart v. USA Lab. for Hire, Inc.

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.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 28th day of April, two thousand twenty-five.

PRESENT: PIERRE N. LEVAL, RICHARD C. WESLEY, RICHARD J. SULLIVAN, Circuit Judges. ______________________________________

KATHYANN SMART,

Plaintiff-Appellee,

v. No. 24-1791

USA LABOR FOR HIRE, INC., RC GLOBAL ENERGY GROUP, INC., OLEG TSIMBLER,

Defendants-Appellants. _______________________________________ For Defendants-Appellants: Garry Pogil, New York, NY.

For Plaintiff-Appellee: Steven Fingerhut, Alexandria Jean- Pierre, Phillips & Associates, Attorneys at Law, PLLC, New York, NY.

Appeal from a judgment of the United States District Court for the Eastern

District of New York (Taryn A. Merkl, Magistrate Judge). 1

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED,

ADJUDGED, AND DECREED that the July 3, 2024 judgment of the district court

is AFFIRMED.

USA Labor for Hire, Inc., RC Global Energy Group, Inc., and Oleg Tsimbler

(together, “Defendants”) appeal from the district court’s denial of their motion for

a new trial or remittitur on plaintiff Kathyann Smart’s claims for a hostile work

environment based on sex, gender, race, and color and retaliation in violation of

Title VII of the Civil Rights Act of 1964 and the New York City Human Rights Law

(the “NYCHRL”) and defamation under New York common law. 2 We assume

1 The parties consented to refer this case to a magistrate judge to conduct all proceedings, including trial, and order the entry of a final judgment in accordance with 28 U.S.C. § 636(c).

2 Defendants also challenge the district court’s refusal to grant a new trial or remittitur on Smart’s claims for a hostile work environment based on national origin and for discriminatory termination. However, the jury found in favor of Defendants on those claims, so any arguments related to them on appeal are moot.

2 the parties’ familiarity with the underlying facts, procedural history, and issues on

appeal.

We review the denial of a motion for a new trial or remittitur for abuse of

discretion. See Sec. & Exch. Comm’n v. DiBella, 587 F.3d 553, 563 (2d Cir. 2009);

Stampf v. Long Island R.R., 761 F.3d 192, 204 (2d Cir. 2014). “[A] motion for a new

trial ordinarily should not be granted unless the trial court is convinced that the

jury has reached a seriously erroneous result or that the verdict is a miscarriage of

justice.” Munafo v. Metro. Transp. Auth., 381 F.3d 99, 105 (2d Cir. 2004) (internal

quotation marks omitted). We also review evidentiary rulings for abuse of

discretion, but “[w]e will not vacate for a new trial . . . if any error was harmless,

i.e., where we can conclude with fair assurance that the evidence did not

substantially influence the jury.” Sheng v. M&TBank Corp., 848 F.3d 78, 84 (2d Cir.

2017) (internal quotation marks omitted).

Defendants first argue that the district court should have granted a new trial

or remittitur because there was insufficient evidence as to Smart’s hostile work

environment claims. Under Title VII, “[a] hostile work environment claim

requires a showing [1] that the harassment was sufficiently severe or pervasive to

alter the conditions of the victim’s employment and create an abusive working

3 environment, and [2] that a specific basis exists for imputing the objectionable

conduct to the employer.” Alfano v. Costello, 294 F.3d 365, 373 (2d Cir. 2002)

(internal quotation marks omitted). We analyze NYCHRL hostile work

environment claims “separately and independently from federal . . . claims”

because “the federal severe or pervasive standard of liability no longer applies to

NYCHRL claims.” Mihalik v. Credit Argicole Cheuvreux N. Am., Inc., 715 F.3d 102,

113 (2d Cir. 2013). Nevertheless, “the NYCHRL is not a general civility code,”

and “a defendant is not liable if the plaintiff fails to prove the conduct is caused at

least in part by discriminatory . . . motives or if the defendant proves the conduct

was nothing more than petty slights or trivial inconveniences.” Id. (citation and

internal quotation marks omitted). Upon reviewing the record in this case, we

conclude that there was ample evidence from which the jury could have

reasonably concluded that Smart was subjected to a hostile work environment

based on sex, gender, race, and color in violation of both Title VII and the

NYCHRL. For example, Smart testified at length about how Tsimbler repeatedly

used racially derogatory and sexist language in reference to her.

Despite this evidence, Defendants argue that a new trial or remittitur was

warranted because the district court permitted Smart to introduce hearsay

4 concerning the meaning of Ukrainian terms that Tsimbler frequently used when

referring to her. Although Smart acknowledged that she does not speak

Ukrainian, she nevertheless testified that a co-worker told her that those words

translated to a disrespectful, derogatory term for a woman. In response to

Defendants’ hearsay objection, the court instructed the jurors that the evidence

was received only “for the fact that the statement was said and [Smart’s]

understanding of it,” not “for the truth of the fact of what it means in Ukrainian.”

But even if we were to assume that the jury disregarded the court’s instruction, the

hearsay would be harmless in light of the wealth of other evidence supporting

Smart’s hostile work environment claims. See United States v. Rivera, 22 F.3d 430,

436 (2d Cir. 1994). Accordingly, we cannot say that the district court abused its

discretion in denying Defendants’ motion for a new trial or remittitur on this

ground.

Defendants next argue that the district court should have granted a new trial

or remittitur on Smart’s retaliation claims because there was insufficient evidence

for the jury to draw a causal connection between any protected activity that Smart

engaged in and her subsequent termination. But Defendants did not raise this

argument before the district court in their motion for a new trial or remittitur, and

5 “[i]t is a well-established general rule that an appellate court will not consider an

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Related

Alfano v. Costello
294 F.3d 365 (Second Circuit, 2002)
Securities & Exchange Commission v. DiBella
587 F.3d 553 (Second Circuit, 2009)
In Re Nortel Networks Corp. Securities Litigation
539 F.3d 129 (Second Circuit, 2008)
Stampf v. Long Island Railroad
761 F.3d 192 (Second Circuit, 2014)
Jia Sheng v. MTBank Corporation
848 F.3d 78 (Second Circuit, 2017)
Liberman v. Gelstein
605 N.E.2d 344 (New York Court of Appeals, 1992)
Felder v. USTA
27 F.4th 834 (Second Circuit, 2022)
Siemens Energy, Inc. v. PDVSA
82 F.4th 144 (Second Circuit, 2023)

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