Stagliano v. Herkimer Central School District

CourtDistrict Court, N.D. New York
DecidedSeptember 4, 2020
Docket6:20-cv-00253
StatusUnknown

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

Bluebook
Stagliano v. Herkimer Central School District, (N.D.N.Y. 2020).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW YORK MARLA STAGLIANO

Plaintiff, v. 6:20-CV-0253 (LEK/TWD) HERKIMER CENTRAL SCHOOL DISTRICT, et al., Defendants. MEMORANDUM-DECISION AND ORDER I. INTRODUCTION Plaintiff Marla Stagliano has brought this action under the Family and Medical Leave Act of 1993 (the “FMLA”), 26 U.S.C. § 2615, against Herkimer Central School District and the Herkimer Board of Education (collectively, “Defendants”). Dkt. No. 1 (“Complaint”). In the Complaint, Plaintiff asserts that Defendants violated the FMLA by retaliating against her through the initiation of disciplinary proceedings under § 3020-a of the New York Education Law. Id. at 6. After the Court granted Plaintiff leave to amend the Complaint, Dkt. No. 21, Plaintiff filed an amended complaint, Dkt. No. 22 (“Amended Complaint”), asserting an additional FMLA claim. Am. Compl. at 6–8. Now before the Court is Plaintiff’s motion for a temporary restraining order and preliminary injunction. Dkt. No. 20-14 (“Plaintiff’s Memorandum of Law”).1 Defendants

1 Plaintiff filed a number of affidavits and deposition transcripts in support of her motion for a temporary restraining order and preliminary injunction, some of which the Court refers to throughout this Memorandum-Decision and Order. See Dkt. Nos. 20-1 (“Plaintiff’s Affidavit”); 20-13 (“Plaintiff’s Deposition”); 20-8 (“Thomas Deposition”); 20-11 (“Richard Deposition”); 20- 12 (“Miller Deposition”). oppose Plaintiffs motion. Dkt. No. 29-10 (“Response”).” For the reasons that follow, the Court denies Plaintiff's motion for a temporary restraining order and preliminary injunction. II. BACKGROUND A. Factual History I. The Parties Plaintiff has taught physical education at Herkimer Central School District since July 1, 2004. See Pl.’s Aff. at 1. She taught at the district’s elementary school until the 2019-20 school year, when she was transferred to the middle school. See id. Defendants are the Herkimer Central School District and the Herkimer Board of Education. Docket. 2. Plaintiff's Prior Lawsuit Against Defendants This is not the first dispute between these litigants to come before this Court. See Stagliano v. Herkimer Cent. Sch. Dist., 151. F. Supp. 3d 264 (N.D.N.Y. 2015) (Kahn, J.) (“Stagliano I’). In Stagliano I, Plaintiff sought, and the Court granted, a temporary restraining order prohibiting these same defendants from conducting a disciplinary hearing against her under New York Education Law § 3020-a. Id. at 277. The disciplinary charges challenged by Plaintiff in Stagliano I stemmed from her postpartum absences from work. Id. at 268. Plaintiff alleged that Defendants violated the FMLA in initiating such charges against her. Id. at 267. The crux of Plaintiffs claim in the instant lawsuit is that she is being retaliated against for this previous exercise of her rights. See Pl.’s Aff. at 4 (“... I was retaliated against for having to

* Defendants filed supporting documents with their Response, some of which the Court refers to throughout its Memorandum-Decision and Order. See Dkt. Nos. 29-3 (“Vogt Affidavit”); 29-4 (“Abbe Affidavit”); 29-5 (“Miller Affidavit”).

defend my FMLA rights in the prior litigation and because defendants continue to ignore the substantive requirements of the FMLA”). The Court began its decision in Stagliano I by recognizing that federal courts must generally abstain from interfering with certain pending state proceedings, including § 3020-a hearings, under Younger v. Harris, 401 U.S. 37 (1971). See Stagliano I at 270-71. However, the Court refused to abstain because the facts triggered the bad-faith exception to Younger abstention. See id. at 271 (“While the Court finds that this action is subject to Younger, it nonetheless finds that Plaintiff has alleged sufficient facts to satisfy the bad-faith exception.”). In applying the bad-faith exception to Younger abstention, the Court noted that “the inference is easy to draw that Defendants are attempting to broadly suppress their employees’ right to use sick leave to care for family, one of the core protections of the FMLA.” Id. at 272. Having reached the merits, the Court in Stagliano I next decided that Plaintiff was entitled to the temporary restraining order she sought. Id. at 276. First, it decided that irreparable harm was likely in the absence of relief because there could be a chilling effect on other teachers’ willingness to take sick leave if they feared disciplinary charges. Id. at 274. Next, the Court determined that the balance of hardships favored Plaintiff over Defendants. Id. at 276. With Defendants enjoined from prosecuting absenteeism-related disciplinary charges against Plaintiff, the parties eventually reached a settlement of Plaintiff's FMLA claims. See Pl.’s Aff. at 3. 3. Plaintiff's Conduct and the § 3020-a Charges Against Her Plaintiff seeks to enjoin Defendants from prosecuting a § 3020-a disciplinary proceeding against her. See PI.’s Aff. at 1. The Court next sets out Plaintiff's conduct that

ostensibly’ led to the initiation of the § 3020-a charges. a. The Counseling Memoranda On August 29, 2018, Plaintiff received a counseling memorandum from Principal Renee Vogt. See PL.’s Aff., Exh. I (the “August 2018 Counseling Memorandum”) at 64; see also Vogt Aff. 7 5. The memorandum alleged that Plaintiff failed to complete a number of end-of-year requirements, including submitting her plan book, grade book, and check-out form. See August 2018 Counseling Memorandum at 64. On December 7, 2018, Plaintiff received a counseling memorandum from Principal Vogt for failing to submit her first-quarter grades. See Pl.’s Aff., Exh. J (the “December 2018 Counseling Memorandum”) at 67; see also Pl.’s Aff. 7 35; Vogt Aff. 7 8. Plaintiff has maintained that the reason for the missed deadline was the district’s failure to indicate when grades were due on its internet calendar. See December 2018 Counseling Memorandum at 67; see also Pl.’s Aff. 7 35. b. The Cell Phone Video Defendants investigated Plaintiff for a video taken on her cell phone during gym class at Herkimer Elementary School on December 12, 2018. See Pl.’s Aff., Exh. D (“Video Investigation”) at 45. The investigation began when a complainant reported that a special education student was being laughed at on the video. See Pl.’s Aff. at 7 13; Video Investigation

> As discussed in detail below, the parties fiercely dispute Defendants’ subjective motivation in prosecuting Plaintiff under New York Education Law § 3020-a. Compare PI.’s Aff. at 1 (“Defendants are seeking to discipline me and terminate my employment in retaliation for prior litigation I brought against defendants for violating rights guaranteed to me by the [FMLA]”) with Response at 18 (“The District has established that numerous legitimate disciplinary reasons exist for its actions regarding the § 3020-a charges that were filed against the Plaintiff in February of 2020.”).

at 45. However, the investigation revealed that the focus of the video was on two adults demonstrating sled-pulling, not the student, who apparently was enjoying himself in the footage. Video Investigation at 45—46. Plaintiff shared the video with a former romantic partner who was on the Board of Education and a current romantic partner who was a district-employed psychologist. See Pl.’s Aff. | 13. Though the investigation found the student had not been ridiculed, the investigator concluded that Plaintiff's creation and dissemination of the video violated school policy regarding student privacy. Video Investigation at 52. c. The May 2019 Meeting On approximately May 1, 2019, during a meeting in the administration office, Plaintiff crumpled a piece of paper, threw it, and cussed. See Vogt Aff.

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Bluebook (online)
Stagliano v. Herkimer Central School District, Counsel Stack Legal Research, https://law.counselstack.com/opinion/stagliano-v-herkimer-central-school-district-nynd-2020.