Baldwin v. Goddard Riverside Community Center
1:11-cv-07591
S.D.N.Y.Sep 29, 2014Background
- Baldwin was hired in July 1994 as Property Manager for Phelps House, a Goddard Riverside affordable housing building.
- Her duties included leasing, building maintenance oversight, and HUD certifications; Rankin was her Administrative Assistant and later Assistant Building Manager.
- Russo became Goddard’s Executive Director in 1998 and directed Hiz operations; Baldwin had a positive early relationship with him.
- From 2005 to 2009 Russo instructed Baldwin to pass over Russian applicants for vacancies, which Baldwin refused as illegal under HUD regulations.
- In late 2008/early 2009 Grenadier replaced the prior management company; Baldwin often resisted transferring duties and used an older computer system during the transition.
- In October 2010, Baldwin was terminated for insubordination related to a bed bug issue; the termination followed a pattern of earlier personnel changes and reorganizations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there a causal link between Baldwin’s protected activities and adverse actions? | Baldwin asserts retaliation for opposing Russia-eligible housing and Robles support. | Goddard contends pre-termination actions were not causally connected to protected activity and timing is inadequate. | No causal connection shown; summary judgment for Goddard on retaliation claims. |
| Do Baldwin’s actions in supporting Robles and testifying at his deposition establish retaliation causal links? | Support for Robles, revisions to insurer, and deposition were protected conduct prompting retaliation. | Actions occurred due to preexisting performance concerns, not retaliation for Robles support. | Temporal proximity insufficient; no prima facie case; summary judgment for Goddard on these claims. |
Key Cases Cited
- Gorman-Bakos v. Cornell Coop. Ext. of Schenectady Cnty., 252 F.3d 545 (2d Cir. 2001) (causal link and temporal proximity standards in retaliation cases)
- Clark Cnty. Sch. Dist. v. Breeden, 532 U.S. 268 (2001) (temporal proximity must be very close to support causation)
- McMenemy v. City of Rochester, 241 F.3d 279 (2d Cir. 2001) (prima facie retaliation elements and minimal burden at outset)
- Gallo v. Prudential Residential Servs., Ltd. P’ship, 22 F.3d 1219 (2d Cir. 1994) (circumstantial proof and burden-shifting framework in retaliation)