Daddino v. Valley Stream Central High School District, 2:16-cv-06638

Background:

Plaintiffs Alphonso Daddino and John Brennan sued Valley Stream Central High School District and three employees (Cecilia Sanossian, Clifford Odell, Bill Heidenreich) alleging hostile work environment and related claims under Title VII, 42 U.S.C. § 1983, and the New York State Human Rights Law (NYSHRL).
Defendants moved for summary judgment: Sanossian moved separately; the District and Odell and Heidenreich (the District Defendants) moved together. Magistrate Judge Lindsay issued an R&R recommending denial of Sanossian’s motion and granting-in-part/denying-in-part the District Defendants’ motion.
Defendants objected to the R&R, arguing (inter alia) that Plaintiffs’ hostile-work-environment claims were not severe or sexual, and that Odell and Heidenreich lacked personal/supervisory involvement; they also challenged Plaintiffs’ compliance with N.Y. Educ. Law § 3813(1) for NYSHRL claims.
The district court reviewed de novo the objections, overruled them, and adopted the R&R in all respects except it deferred ruling on the § 3813(1) notice-of-claim issue. The court held Sanossian’s summary judgment motion was denied; the District Defendants’ motion was granted in part and denied in part.
The court noted the Second Circuit’s post-Iqbal decision in Tangreti (on supervisory liability) had not been briefed by the parties; the court therefore declined to decide Tangreti’s impact but allowed the parties to address it before trial. The § 3813(1) question (and Carter v. Syracuse) is likewise deferred.

Issues:

Issue	Plaintiff's Argument	Defendant's Argument	Held
Hostile work environment (Title VII, §1983, NYSHRL)	Plaintiffs say Sanossian’s comments/touches created a hostile, sexually discriminatory environment	Defendants say conduct was not severe/pervasive or sexual; similar to conduct toward women; touching not sex-motivated	Objections overruled; R&R adopted — a reasonable jury could find for Plaintiffs; summary judgment denied as to Sanossian on these claims
§1983 causation standard	Plaintiffs argue evidence supports harassment liability	Defendants argue §1983 requires "but-for" causation (stricter) and Plaintiffs cannot meet it	Court: although §1983 uses but-for, a reasonable jury could find for Plaintiffs under that standard; objection overruled
Supervisory liability for Odell & Heidenreich	Plaintiffs rely on supervisory-liability avenues (as applied by Colon pre-Iqbal) to hold supervisors individually liable	Defendants argue lack of personal involvement and, at minimum, qualified immunity; they relied on Colon-era tests in briefing	Objections overruled; court declines to resolve Tangreti’s post-Iqbal impact (parties may brief before trial); §1983 claims against them survive for now
N.Y. Educ. Law §3813(1) notice-of-claim for NYSHRL claims	Plaintiffs contend their internal harassment complaints and agency filings suffice; District Compliance Officer may be analogous to board-designated agent	District relies on Carter (service must be on board or designated agent; service on superintendent insufficient)	Court deferred ruling on §3813(1) issue (will address after resolving §1983 viability against Odell/Heidenreich and after additional briefing)

Key Cases Cited

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (established pleading standards and limited doctrines for supervisory liability)
Tangreti v. Bachmann, 983 F.3d 609 (2d Cir. 2020) (post-Iqbal decision holding there are no sui generis supervisory-liability rules separate from ordinary tort principles)
Colon v. Coughlin, 58 F.3d 865 (2d Cir. 1995) (articulated prior special tests for supervisory liability)
Pall Corp. v. Entegris, Inc., 249 F.R.D. 48 (E.D.N.Y. 2008) (standard of review for magistrate judge R&R rulings without specific objections)
Carter v. Syracuse City Sch. Dist., [citation="850 F. App'x 22"] (2d Cir. 2021) (notice-of-claim under N.Y. Educ. Law § 3813(1) requires service on the board or its designated agent; service on superintendent held insufficient)