Matthew L. Berman
Class actions · Employment · Civil rights
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Wright v White Plains Hosp. Med. Ctr.

237 A.D.3d 1143, 232 N.Y.S.3d 594, 2025 N.Y. Slip Op. 02371

Appellate Division, Second Department · April 23, 2025

What the court decided

For claims filed on or after August 12, 2019, the State Human Rights Law must "be construed liberally for the accomplishment of the remedial purposes thereof, regardless of whether federal civil rights laws ... have been so construed" (Executive Law § 300). As a result, the court said, the State law "now aligns with the standards of the New York City Human Rights Law," under which discrimination must play "no role" in an employment decision, so an employer moving for summary judgment must show there is "no evidentiary route that could allow a jury to believe that discrimination played a role." A probationary phlebotomist who was fired and claimed pregnancy discrimination offered only speculation, so her claim was dismissed.

Who won

The employer won. The Appellate Division affirmed summary judgment dismissing the complaint.

Why it matters for workers with a medical condition

The State law is now read much more like the City law than like federal law. That helps workers across the State, but it does not replace evidence: a claim still needs facts suggesting discrimination played a role.

Key passage: 237 A.D.3d at 1144–46.

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