Daddino v. Valley Stream Central High School District
2:16-cv-06638
E.D.N.YFeb 25, 2022Background
- Plaintiffs Alphonso Daddino and John Brennan are tenured social-studies teachers at Valley Stream North who allege repeated sexualized comments and frequent unwanted touching by Social Studies Department Chair Cecilia Sanossian over several years.
- Brennan made a written complaint to principal Odell on February 13, 2015; a joint written complaint by nine department members (including Daddino) was submitted May 1, 2015. Plaintiffs filed NYSDHR/EEOC charges on August 24, 2015 and this federal suit on November 30, 2016.
- Odell investigated multiple complaints, produced a report finding insufficient evidence of actionable sexual harassment, and the District issued a counseling memorandum to Sanossian (not formal discipline).
- Plaintiffs assert Title VII, NYSHRL and Section 1983 hostile-work-environment and retaliation claims against the District, Odell, Heidenreich, and Sanossian (individual capacity). Defendants moved for summary judgment; Sanossian separately moved for summary judgment.
- Magistrate Judge Lindsay recommends denying Sanossian’s motion and granting in part / denying in part the District defendants’ motion: hostile-work-environment claims under Title VII, NYSHRL and §1983 survive; retaliation claims against the District defendants dismissed but retaliation claim against Sanossian survives.
- The magistrate applied the continuing-violation doctrine to preserve acts outside ordinary filing windows and rejected the District’s notice-of-claim defense under N.Y. Educ. Law §3813 as a basis for dismissal on these facts.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Timeliness/statute of limitations for Title VII, §1983, NYSHRL claims | The harassment was continuous from 2009–2015; continuing-violation doctrine renders older incidents timely | Many incidents predate limitations periods and thus are time-barred | Court applied continuing-violation doctrine; entire 2009–2015 period considered timely |
| Notice-of-claim under N.Y. Educ. Law §3813 for NYSHRL claims against District | Plaintiffs gave adequate notice via written complaints and agency filings | District contends plaintiffs failed to file the formal notice required by §3813 | Court found plaintiffs’ notices substantially complied and declined dismissal on §3813 grounds |
| Hostile work environment / employer liability (Title VII, NYSHRL, §1983) | Conduct was frequent, sexualized, and directed more intensely at male teachers; District failed to correct it | Conduct was merely annoying/incidental touching; District had policy and investigated (Faragher/Ellerth defense) | Triable issues exist as to severity, sex‑based motive, and adequacy of District’s corrective measures; harassment claims survive summary judgment |
| Retaliation (against District and Sanossian) | Filing complaints and media/agency activity were protected; Sanossian’s lawsuits and District’s handling were retaliatory | Failure-to-investigate or to reassign is not an adverse action; Sanossian’s suits were non-retaliatory meritorious litigation | Retaliation claims dismissed as to District defendants (no adverse employment action); retaliation claim against Sanossian allowed to proceed |
Key Cases Cited
- Harris v. Forklift Sys., Inc., 510 U.S. 17 (1993) (standard for hostile work environment under Title VII)
- Meritor Sav. Bank, FSB v. Vinson, 477 U.S. 57 (1986) (recognition of hostile-work-environment liability)
- Oncale v. Sundowner Offshore Servs., Inc., 523 U.S. 75 (1998) (conduct must be objectively and subjectively hostile; social context matters)
- Redd v. New York Div. of Parole, 678 F.3d 166 (2d Cir. 2012) (hostile-environment analysis and supervisory harassment)
- Faragher v. City of Boca Raton, 524 U.S. 775 (1998) (employer affirmative defense when no tangible employment action)
- Burlington N. & Santa Fe Ry. Co. v. White, 548 U.S. 53 (2006) (retaliation adverse-action standard—reasonable employee test)
- Pearson v. Callahan, 555 U.S. 223 (2009) (qualified immunity framework)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (summary judgment standard)