Camarda v. Selover, 673 F. App'x 26

Plaintiff Mary Ann Camarda, an NYPD officer, sued the City and several supervisors alleging sex discrimination, hostile work environment, and retaliation under § 1983, Title VII, the NYSHRL, and the NYCHRL.
The district court granted summary judgment to defendants; Camarda appealed only certain rulings and did not challenge the Monell dismissal or some individual-defendant dismissals.
Key contested facts: disciplinary actions (desk/detail assignments, reprimands for attire, failure to have memo book, retyping summons), remarks by supervisors (e.g., “you are a girl and you can’t type,” and comments about low-cut shirts), and testimony from coworkers suggesting unfair targeting.
Defendants conceded some actions were taken but asserted the actions were non-discriminatory and applied to male officers similarly.
The district court excluded certain coworker statements as hearsay and found insufficient evidence to infer sex-based motive; Second Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Camarda established a prima facie sex-discrimination claim under § 1983/Title VII/NYSHRL	Testimony and remarks show supervisors targeted her because she was female; disparate treatment and sexist comments support inference of discrimination	Discipline was justified by misconduct; male officers received similar discipline; stray remarks and disputed testimony insufficient to prove discriminatory motive	Affirmed: insufficient evidence to create an inference of discrimination; summary judgment for defendants affirmed
Whether Camarda established a claim under NYCHRL	Remarks and treatment show employer treated her less well in part due to sex	Employer had legitimate, non-discriminatory reasons for actions	Affirmed: record established as a matter of law that discrimination played no role
Whether hostile work environment and retaliation claims survived summary judgment	Harassment and subsequent adverse actions demonstrate hostile environment and retaliation for complaint	Claims abandoned by plaintiff in opposing summary judgment; alternatively insufficient proof	Affirmed: court inferred abandonment; declined to reach merits
Admissibility of coworker statements claiming supervisors ‘‘didn’t want her around because she is female’’	Statements are probative of motive	Statements are hearsay and inadmissible on summary judgment	Affirmed: statements inadmissible hearsay and not considered

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden-shifting framework for discrimination claims)
Ya-Chen Chen v. City Univ. of N.Y., 805 F.3d 59 (NYCHRL claims analyzed independently and more liberally)
Mihalik v. Credit Agricole Cheuvreux N. Am., Inc., 715 F.3d 102 (NYCHRL standard and employer may rebut by showing discrimination played no role)
McPherson v. New York City Dep’t of Educ., 457 F.3d 211 (focus on employer motivation, not merely allegations against plaintiff)
Rubens v. Mason, 387 F.3d 183 (on summary judgment, courts may rely only on evidence admissible at trial; hearsay excluded)