Carter v. The City of Syracuse School District, 5:10-cv-00690

Background:

Corene Carter, a Black female high-school English teacher at Syracuse Institute of Technology, sued the Syracuse City School District and three administrators alleging race- and gender-based discrimination, hostile work environment, retaliation, and municipal liability.
Procedural history: multiple pleadings and motions; the district court previously dismissed many claims; the Second Circuit vacated some dismissals, ordered additional fact discovery (including deposition of Ben Frazier), and remanded for reconsideration in light of Margerum v. City of Buffalo.
Defendants moved for summary judgment (2017). The court first addressed whether Carter may pursue an HRL claim against the District and Superintendent in light of New York Education Law notice requirements and Margerum.
The court found Carter did not present her notice of claim to the Board of Education as required by N.Y. Educ. Law § 3813, so HRL claims against the District and Superintendent were dismissed.
On the remaining claims, the court applied McDonnell Douglas burden-shifting and related hostile-work-environment standards and concluded: (1) alleged incidents (negative evaluation/assistance plan, loss of chair, interruptions, mockery) were not materially adverse or sufficiently severe/pervasive; (2) no triable evidence of individual defendants’ personal involvement; (3) no Monell municipal liability; and (4) Title VII retaliation failed because Carter did not follow the collective-bargaining transfer procedure, so she was not denied a transfer.
Judgment: the court granted summary judgment for defendants on all remaining federal and state claims and ordered the case closed.

Issues:

Issue	Plaintiff's Argument	Defendant's Argument	Held
1) Whether HRL claims against the School District and Superintendent survive after Margerum	Carter contended she filed and served a notice of claim and Margerum eliminates GML notice requirement for HRL claims	Defendants argued Education Law §3813 requires presentment to the Board of Education and Carter did not present to the Board	Dismissed: Carter failed to present the notice to the Board as §3813 requires; Margerum did not negate §3813's separate requirement
2) Whether Carter established adverse employment actions (McDonnell Douglas prima facie)	Carter identified negative evaluation/assistance plan, removal as department chair, loss of class assignments, classroom disruptions, scrutiny, mockery	Defendants said assistance plan non‑disciplinary, many incidents isolated or unsupported, and no tangible losses or causal link to race/gender	Granted for defendants: evidence does not show materially adverse actions or causal inference of discrimination
3) Whether workplace conduct amounted to a hostile work environment under Title VII/§1983	Carter cited remarks, alleged evaluative pretext, racist comments by coworkers, and alleged targeting/over‑scrutiny	Defendants argued incidents were isolated/minor, many not reported to supervisors, and no proof supervisors created or knew of a pervasive hostile environment	Granted for defendants: conduct not sufficiently severe or pervasive; no supervisory personal involvement established
4) Whether the District is liable under §1983 (Monell)	Carter argued custom/policy evidence (affidavits from other teachers) supports municipal liability	Defendants argued no policymaker caused constitutional violation and alleged incidents were isolated and factually disconnected	Granted for defendants: no underlying constitutional violation by a policymaker and affidavits describe isolated, unrelated events
5) Whether Title VII retaliation claim (transfer denial) survives	Carter asserted she sought transfer via psychiatrist’s notes after NYSDHR complaint and was effectively denied because transfers are typically granted	Defendants argued the CBA prescribes a formal transfer request procedure, which Carter did not follow; psychiatrist notes were not a request	Granted for defendants: Carter did not make a formal transfer request under the contract, so no adverse retaliatory transfer denial proved

Key Cases Cited

Margerum v. City of Buffalo, 24 N.Y.3d 721 (N.Y. 2015) (HRL claims not subject to GML notice requirement but Education Law may impose separate notice duties)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (three-step burden-shifting framework for disparate-treatment claims)
Vega v. Hempstead Union Free Sch. Dist., 801 F.3d 72 (2d Cir. 2015) (applying McDonnell Douglas and defining adverse employment actions)
Burlington Northern & Santa Fe Ry. Co. v. White, 548 U.S. 53 (U.S. 2006) (standard for materially adverse actions in Title VII retaliation claims)
Harris v. Forklift Sys., Inc., 510 U.S. 17 (U.S. 1993) (hostile-work-environment severity/pervasiveness standard)
Monell v. Dep’t of Soc. Servs. of City of New York, 436 U.S. 658 (U.S. 1978) (municipal liability under §1983 requires official policy or custom causing the violation)
Desert Palace, Inc. v. Costa, 539 U.S. 90 (U.S. 2003) (motivating-factor standard for discrimination causation)
Littlejohn v. City of New York, 795 F.3d 297 (2d Cir. 2015) (personal involvement and supervisor liability under §1983)