Dixon v. International Federation of Accountants
416 F. App'x 107
2d Cir.2011Background
- Dixon sued IFAC and individuals for employment discrimination under Title VII, ADEA, §1981, NYSHRL, and NYCHRL, plus state law claims.
- The district court granted summary judgment for defendants and denied Dixon's motion for partial summary judgment.
- Dixon alleged discrimination based on age, race, and national origin, and retaliation after complaining of discrimination.
- Defendants argued Dixon was terminated for deficient work performance, not due to protected characteristics or retaliation.
- Dixon's retaliation claim rested on temporal proximity between her June 2007 complaint to Ball and October 2007 termination; no direct evidence of causation.
- The Second Circuit affirmed, holding no genuine discrimination or retaliation issues and proper exercise of supplemental jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Prima facie discrimination established? | Dixon claims termination due to protected status. | IFAC terminated for deficient performance. | No discrimination; stray remark insufficient; legitimate reason shown. |
| Retaliation sufficient to survive summary judgment? | Termination followed protected activity; temporal proximity evidences retaliation. | Temporal proximity alone is insufficient without evidence of causation or pretext. | No causal link; pretext not shown; dismissal proper. |
| Supplemental jurisdiction over non-federal claims? | Jurisdiction was improper for state/city claims. | Claims derive from same nucleus of operative fact as federal claims. | No abuse of discretion; jurisdiction proper. |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (Supreme Court 1973) (establishes burden-shifting framework for discrimination claims)
- Gorzynski v. JetBlue Airways Corp., 596 F.3d 93 (2d Cir. 2010) (continues McDonnell Douglas framework for ADEA/Title VII/§1981)
- Danzer v. Norden Systems, Inc., 151 F.3d 50 (2d Cir. 1998) (stray remarks do not prove discrimination)
- Slattery v. Swiss Reinsurance Am. Corp., 248 F.3d 87 (2d Cir. 2001) (legitimate reasons may defeat discrimination claim)
- Clark County Sch. Dist. v. Breeden, 532 U.S. 268 (Supreme Court 2001) (temporal proximity must be very close to show retaliation)
- Valencia ex rel. Franco v. Lee, 316 F.3d 299 (2d Cir. 2003) (supplemental jurisdiction analyzed under related claims)
- City of Chicago v. Int’l Coll. Of Surgeons, 522 U.S. 156 (Supreme Court 1997) (nexus between related claims for supplemental jurisdiction)
- Burg v. Gosselin, 591 F.3d 95 (2d Cir. 2010) (summary judgment standard and burden shifting)