Alaei v. State University of New York at Albany
1:21-cv-00377
N.D.N.Y.May 30, 2025Background
- Dr. Kamiar Alaei alleges Title IX sex discrimination after SUNY Albany chose not to renew his employment.
- The University’s decision followed a joint Title IX and HR investigation addressing (a) his alleged involvement in his brother’s university activity after separation, and (b) allegations of sexual misconduct by Dr. Alaei.
- The investigative report created during the process was not finalized, was unsigned, and omitted Dr. Alaei's perspective.
- The case is proceeding to trial, and this opinion resolves several pretrial evidentiary motions (motions in limine).
- Both parties dispute the admissibility of certain evidence, notably the investigative report, medical records, potential impeachment of a witness, and damages evidence.
- The judge grants some requests, denies others, and directs further briefing on unresolved evidentiary issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of Investigative Report | Report is unreliable, one-sided, unfairly prejudicial | Report is business record and key context for decision | Inadmissible; probative value outweighed by risk of prejudice/confusion |
| Testimony from Investigative Witnesses | Witnesses not relevant; not decision-makers | Needed to explain decision process to jury | May be partially admissible; further briefing required |
| Plaintiff’s Medical Testimony (Without Experts) | Should be able to describe own symptoms | Testimony about medical effects needs expert support | Plaintiff can testify to symptoms, not causation absent expert, unless causal link is common sense; final ruling reserved |
| Admissibility of Medical Records | Will call providers to lay foundation | Medical records require proper authentication | Denied as moot; Plaintiff listing providers as witnesses resolves objection |
| Impeaching Botticelli with Prior Legal Decision | Should allow impeachment for bias/misjudgment | Should be excluded as prior bias claim was ultimately rejected | Allowed for impeachment within limits; risk of 'trial within a trial' will be managed at trial |
| Admissibility of Collateral Estoppel Evidence | Some claims from previous Court of Claims action are preclusive | Would confuse jury and cause prejudice | Further briefing required |
| Damages Evidence (fringe benefits/lost opp./medical) | Can testify to benefits, losses | Lacks proper evidence/disclosure; expert needed | Further briefing ordered |
| Punitive Damages | Not seeking punitive damages | State agency not subject to punitive damages | Denied as moot |
| Previously Dismissed Claims | Only Title IX claim remains | Exclude evidence of other claims | Denied as moot |
| Specific Dollar Demand at Trial | Will not ask jury for specific dollar figure | Preclude specific demand | Denied as moot |
| Undisclosed Witnesses | No undisclosed witnesses listed | Preclude their testimony | Denied as moot |
Key Cases Cited
- Paolitto v. John Brown E. & C., Inc., 151 F.3d 60 (2d Cir. 1998) (outlines standard for admissibility and trustworthiness of HR investigative reports)
- Evans v. Ottimo, 469 F.3d 278 (2d Cir. 2006) (collateral estoppel - identity of decided issues and full/fair opportunity to litigate)
- Sullivan v. Gagnier, 225 F.3d 161 (2d Cir. 2000) (collateral estoppel definition)
- Schwartz v. Public Adm’r of Cnty. of Bronx, 24 N.Y.2d 65 (N.Y. 1969) (identity of issue requirement for collateral estoppel)