Washington v. NETworks Presentations, LLC

CourtDistrict Court, S.D. New York
DecidedMarch 31, 2025
Docket1:24-cv-00299
StatusUnknown

This text of Washington v. NETworks Presentations, LLC (Washington v. NETworks Presentations, LLC) 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
Washington v. NETworks Presentations, LLC, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ZURI WASHINGTON, Plaintiff, 1:24-cv-00299 (ALC) -against- OPINION & ORDER NETWORKS PRESENTATIONS, et al., Defendants.

ANDREW L. CARTER, JR., United States District Judge

Plaintiff Zuri Washington ( “Plaintiff” or “Washington”) filed a civil complaint alleging racial discrimination and retaliation in violation of Title VII of the Civil Rights Act of 1964 (“Title VII”), Section 1981 of the Civil Rights Act of 1866 (“Section 1981”), the New York State Human Rights Law, N.Y. Exec. Law § 296, et seq. (“NYSHRL”), and the New York City Human Rights Law, N.Y.C. Admin. Code § 8-101, et seq. (“NYCHRL”). This complaint was brought against Defendants NETworks Presentations, LLC (“NETworks”), 1776 Touring LLC (“1776 Touring”), National Artists Management Company, Inc. (“NAMCO”), and Gentry & Associates, Inc. (“Gentry”) (together “Corporate Defendants”), and Trinity Wheeler, Gregory Vanderploeg, Madeline McCluskey, and Katie Cortez (together “Individual Defendants,” and with Corporate Defendants, “Defendants”). ECF No. 51 (“AC”).1 Washington alleges that she was subject to discriminatory treatment by the Individual Defendants and was unreasonably terminated in retaliation for concerns she raised about the alleged discrimination. Id.

1 On April 19, 2024, Plaintiff filed her amended complaint. ECF No. 32. This filing was deficient, and Plaintiff refiled the amended complaint on December 6, 2024. ECF No. 51. Defendants moved to dismiss the amended complaint, and their motion, briefing, and responsive briefing all referenced the deficient amended complaint at ECF No. 32. Therefore, this opinion still pertains to the amended complaint, even though it was formally filed after the instant motion. On May 17, 2024, Defendants filed a motion to dismiss the amended complaint. ECF No. 38. In their opening brief, Defendants argue that this Court does not have personal jurisdiction over Defendants. ECF No. 40. They additionally argue that, even if this Court does have personal jurisdiction over them, Plaintiff fails to state a claim and that the Southern District of New York

in an improper venue. Id. Defendants move to dismiss the complaint or, at minimum, to transfer it to the District of Maryland. Id. For the reasons set forth below, the motion is GRANTED. BACKGROUND I. Factual History Plaintiff is a Black woman who works as a classically trained actor. AC ¶ 6. In December of 2022, she was hired to play a role in the production of 1776 (“the Show”)—a musical about the United States’ founding. She signed her contract to join the production in New York, where she auditioned and was cast. AC ¶ 86. The show originally debuted in 1969, but this modern rendition aimed to tell this story through a new lens, by “exclusively starr[ing] multi-racial actors who identify as female, nonbinary, and/or transgender — groups that were shut out from and never

considered during the drafting of the Declaration of Independence — as opposed to a cast historically of white men.” AC ¶ 2. The Show was produced by Defendant NETworks, a large company that has produced several touring Broadway shows. ECF No. 40. The company was also the party responsible for establishing Defendant 1776 Touring as the employer agency for the Show. AC ¶¶ 55, 71. As the employer agency, 1776 Touring entered into contracts with the Show’s employees and paid cast members’ wages. Id. NETworks’ and 1776 Touring’s principal places of business are in Maryland. AC ¶¶ 47, 49. Defendant Gentry is the corporation which served as the general manager for the Show, according to an agreement with NETworks. Gentry’s principle place of business is in Maryland. AC ¶¶ 55, 71. Defendant NAMCO is an entertainment production company with its principal place of business in New York. Id. ¶ 51. NAMCO is listed as a producer of 1776 and a member of the Broadway League—a collective bargaining unit representing Broadway show producers. Id. ¶ 79. The Individual Defendants—Trinity Wheeler, Gregory Vander Ploeg,

Madeline McCluskey, and Katie Cortez—are all domiciled in either South Carolina, Texas, or Maryland. ECF No. 40 at 3. Before the show was brought to consumers, a period of rehearsals took place in Utica, New York. During this time, Plaintiff made a request for more information about what her hair plan for the Show would be given particular care needs her hair required. AC ¶¶ 11–16. The plan for Washington’s hair—including choices around styling, use of a wig, etc.—was solely under the discretion of 1776 Touring, as specified by their employment agreement. See ECF No. 39-1 ¶ 17. In December of 2022, while in New York City, Plaintiff had a consultation with the Show’s Associate Hair Designer, and Plaintiff further inquired about what the plan for her hair would be. ECF No. 40 at 4. Washington requested to wear either a wig or a braided protective style to ensure

her hair remained healthy while on tour. Id. She repeatedly made such requests during the rehearsal period in Utica. AC ¶¶ 93–103. Despite her requests, Washington was not informed of her hair plan for four months. Id. Plaintiff alleges that other Black actors were similarly left without guidance as to their hair plans, while white actors were provided with wigs on demand. AC ¶ 12. Plaintiff argues that this differential treatment was racially discriminatory against her as a Black woman. Plaintiff further alleges Defendants discriminated against her during a separate incident. After Washington expressed frustration at a meeting in Philadelphia concerning the Show’s handling of a COVID-19 infection, Defendant Madeline McCluskey, the Show’s acting General Manager, notified Washington’s agent about Plaintiff’s “unruly behavior.” Id. ¶ 19. Washington’s agent was the only agent called about this meeting, even though multiple other cast members expressed their agitation with production. Id. ¶ 21; see also id. ¶¶ 118–121. Considered along with the unresponsiveness regarding Black cast members’ hair plans, Plaintiff furthers suspect her race

played a part in her agent’s notification. Id. ¶ 25. While Plaintiff was on tour in Denver, she met with the Show’s Human Resources (HR) representative—who was in Maryland—via videoconference to express her concerns about the production team, particularly regarding what the alleged racial discrimination. Id. ¶ 27. In a second meeting, the HR representative relayed to Washington that the production team would not apologize for their action and explained her option to file a discrimination complaint. ECF No. 40 at 7. Washington became agitated, stating, “I’ll take these fuckers down that way if I have to. I’ve taken bigger fuckers down before and I’ll do it again. So yes, I will be filing an official complaint with HR.” AC ¶ 150. Afterwards, HR relayed this conversation to the production team, who discussed the events

in Maryland. March 24, 2023, two hours after meeting with HR, Plaintiff was terminated. Id. ¶ 152. She subsequently received an official letter of termination citing “aggressive, uncontrolled behavior and threatening statements,” as the basis of her termination. Id. ¶ 153. Plaintiff alleges that this termination is evidence of her disparate treatment and retaliation for her planned discrimination complaint. Id. ¶¶ 36–37. Defendants argue the termination was justified because of Plaintiff’s behavior in the COVID-19 meeting and meetings with HR. ECF No. 40 at 19–20. II. Procedural History On January 16, 2024, Plaintiff filed a complaint against Defendants seeking compensatory damages for mental, emotional, and physical pain and suffering, punitive damages, compensation for lost wages and benefits, and attorneys’ fees and expenses. See generally AC at 34.

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Washington v. NETworks Presentations, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/washington-v-networks-presentations-llc-nysd-2025.