Chiaramonte v. Animal Medical Center
677 F. App'x 689
2d Cir.2017Background
- Plaintiff Deirdre Chiaramonte, a veterinarian and Director of the President’s Council and Rehabilitation Center at The Animal Medical Center (AMC), sued under the federal Equal Pay Act (EPA) and New York Labor Law § 194 alleging pay discrimination vs. higher‑paid male veterinarian colleagues.
- Defendants are AMC and its CEO Kathryn Coyne; the district court granted summary judgment for defendants, dismissing federal claims and declining supplemental jurisdiction over state claims.
- Chiaramonte argued her role as a department head with administrative duties and some clinical/rehab work was substantially equal to male department‑head veterinarians who were paid more.
- AMC showed the male comparators practiced medical specialties, performed more complex procedures, had higher patient loads, supervised interns/other vets, and contributed to research/teaching—distinguishing their actual job content from Chiaramonte’s.
- Chiaramonte also offered company‑wide pay lists/statistics and contested the district court’s reliance on an affidavit by AMC’s Dr. Goldstein; the district court found her comparators were not substantially equal, rejected the raw pay lists, and relied on uncontradicted testimony.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether plaintiff performed "substantially equal" work to higher‑paid male veterinarians under the EPA | Chiaramonte: all were department heads with similar credentials and responsibilities, so jobs are substantially equal | AMC: actual job content differs materially (specialties, complexity, patient load, supervision, research/teaching) | Held for AMC—jobs not substantially equal; plaintiff failed to meet EPA element |
| Whether company‑wide pay disparities can substitute for a lacking specific comparator | Chiaramonte: company‑wide pay patterns show across‑the‑board discrimination and may be considered | AMC: raw lists without job‑content control are unreliable and do not identify a true comparator | Held for AMC—generic pay lists/statistics insufficient absent a proper comparator and appropriate analysis |
| Whether the district court erred by relying on testimony of an "interested" AMC witness (Dr. Goldstein) | Chiaramonte: interested witness credibility is for the jury; affidavit should not decide material facts on summary judgment | AMC: Dr. Goldstein’s testimony was uncontradicted and admissible; lack of contradictory evidence means it may be credited on summary judgment | Held for AMC—uncontradicted testimony did not create a genuine dispute of material fact |
| Whether dismissal of federal claims required dismissal of pendent state‑law claims | Chiaramonte: (implicit) wished to retain state claims | AMC: where federal claims dismissed, court should decline supplemental jurisdiction | Held for AMC—district court properly dismissed state claims after granting summary judgment on federal claims |
Key Cases Cited
- McBride v. BIC Consumer Prods. Mfg. Co. Inc., 583 F.3d 92 (2d Cir.) (standard of review for summary judgment)
- Anderson v. Liberty Lobby, 477 U.S. 242 (U.S.) (nonmovant must present specific facts creating genuine dispute)
- Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (U.S.) (nonmovant must do more than create metaphysical doubt)
- E.E.O.C. v. Port Auth. of N.Y. & N.J., 768 F.3d 247 (2d Cir.) (EPA requires jobs be "substantially equal" based on actual job content)
- Tomka v. Seiler Corp., 66 F.3d 1295 (2d Cir.) (EPA inquiry focuses on job content, not title)
- Burlington Indus., Inc. v. Ellerth, 524 U.S. 742 (U.S.) (cited for abrogation context on precedent—not central to holding here)
- Fisher v. Vassar College, 70 F.3d 1420 (2d Cir.) (professors with same title may still fail EPA proof absent equivalent job content)
- Lavin‑McEleney v. Marist Coll., 239 F.3d 476 (2d Cir.) (statistical company‑wide evidence may support an EPA claim only alongside a proper comparator and appropriate analysis)
- Reeves v. Sanderson Plumbing Prods., 530 U.S. 133 (U.S.) (credibility assessments generally for jury; but uncontradicted testimony can support summary judgment)
- In re Dana Corp., 574 F.3d 129 (2d Cir.) (summary judgment considerations; jury’s role in credibility)