Boston v. Taconic Eastchester Management LLC, 1:12-cv-04077

Brett Boston, an African American superintendent at Eastchester Heights since 1988, was supervised by Maintenance Manager Savath Pauv; Taconic managed the property from 2007.
Boston alleges discriminatory treatment and repeated comments by Pauv about his dreadlocks and attire, but never filed an internal or union discrimination complaint before termination.
Taconic had a zero-tolerance theft policy and a centralized supply-room procedure requiring attendants to log items and verify work orders.
On March 8, 2012 Boston took lightbulbs plus Pine-Sol and Tilex not listed on his work order; supply-room attendant Bier logged the items and reported the incident to supervisors.
Taconic managers (Woodruff, Febo, McInerney) decided to terminate Boston for taking unauthorized supplies; Boston grieved through the union but did not assert discrimination in the grievance; the union declined arbitration.
Boston sued under Title VII (race/color), ADEA (later withdrawn), NYSHRL, and NYCHRL alleging discrimination, hostile work environment, retaliation, and aider-and-abettor liability; the court granted summary judgment for defendants.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Race/color termination (Title VII)	Boston says termination was pretext for discrimination because he did not steal and managers relied on Pauv’s bias	Taconic contends legitimate nondiscriminatory reason: theft of supplies following supply-room procedures and warnings	Summary judgment for Taconic: employer offered legitimate reason and Boston failed to show pretext
Hostile work environment	Pauv’s comments about dreadlocks, clothing, and comparisons created a racially hostile workplace	Taconic: comments were isolated, often race-neutral, and insufficiently severe or pervasive	Summary judgment for Taconic: comments not severe or pervasive enough to create hostile environment
Retaliation	Boston claims termination was in retaliation for complaining to Pauv about discriminatory comments/assignments	Taconic: termination was for theft; no evidence that complaint motivated firing	Summary judgment for Taconic: plaintiff failed to show pretext or causal link
Cat’s-paw (imputing supervisor bias)	Boston argues Taconic negligently relied on Pauv’s alleged animus	Taconic: decision was made by higher management after consulting Bier and others; Pauv did not fabricate facts or control decision	Summary judgment for Taconic: no negligent reliance; record shows independent investigation and decision by management

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden-shifting framework for discrimination claims)
Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burden allocation)
Anderson v. Liberty Lobby, 477 U.S. 242 (standard for genuine dispute of material fact)
Harris v. Forklift Systems, Inc., 510 U.S. 17 (hostile work environment standards)
Jute v. Hamilton Sundstrand Corp., 420 F.3d 166 (applying McDonnell Douglas to retaliation)
Gordon v. New York City Board of Education, 232 F.3d 111 (pretext and discriminatory motive formulation)
Tolbert v. Smith, 790 F.3d 427 (requirement of more than isolated racist comments for hostile work environment)