Frederick v. United Brotherhood of Carpenters, 665 F. App'x 31

Nakeisha Frederick (pro se) sued her former employer, the United Brotherhood of Carpenters, alleging Title VII claims: failure to promote, unequal terms/pay, retaliation, hostile work environment, and termination.
The district court dismissed most claims in an order and later granted summary judgment to the Union on the remaining disparate-pay claim (initial pay rate lower than another employee).
Frederick filed a notice of appeal that did not precisely identify the district-court order date; the Second Circuit construed the notice liberally to encompass both the dismissal order and the summary-judgment order.
The Second Circuit reviewed the dismissal de novo under federal pleading standards and Title VII causation principles and reviewed summary judgment de novo, viewing evidence in the light most favorable to Frederick.
The court affirmed dismissal of failure-to-promote, termination, hostile-environment, pay-disparity with prior managers, and retaliation claims, finding insufficient factual allegations to support an inference of discrimination.
The court affirmed summary judgment on the initial pay-rate claim because Frederick offered no evidence of discriminatory intent; she attributed the lower rate to her weaker bargaining position.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the notice of appeal properly invoked this Court's jurisdiction	Frederick intended to appeal the district-court judgment	Union argued the notice failed to designate the first order and so limited appeal	Court construed pro se notice liberally and found it designated the judgment, bringing up both orders
Whether the complaint plausibly alleged Title VII discrimination for failure to promote and termination	Frederick alleged conspiracy to fire/hire cronies and discriminatory motives	Union argued allegations showed favoritism/nepotism, not race-based animus	Dismissal affirmed: allegations did not support inference of protected-class animus
Whether hostile work environment and retaliation claims were sufficiently pleaded	Frederick alleged harassment and retaliatory conduct leading to adverse actions	Union argued facts did not show adverse actions motivated by protected characteristics	Dismissal affirmed for failure to plead facts plausibly showing discriminatory or retaliatory motivation
Whether summary judgment was improper on disparate-pay claim (initial pay rate)	Frederick contended her initial hourly rate was lower than another employee's, implying discrimination	Union argued Frederick offered no evidence of discriminatory intent; she admitted lower pay reflected bargaining position	Summary judgment affirmed: no evidence raising an inference of discrimination

Shrader v. CSX Transp., 70 F.3d 255 (2d Cir. 1995) (liberal construction of notice of appeal)
New Phone Co., Inc. v. City of New York, 498 F.3d 127 (2d Cir. 2007) (appealability depends on clear intent to appeal)
Littlejohn v. City of New York, 795 F.3d 297 (2d Cir. 2015) (circumstances that may give rise to an inference of discrimination)
Vega v. Hempstead Union Free Sch. Dist., 801 F.3d 72 (2d Cir. 2015) (pleading causation for Title VII claims)
Village of Freeport v. Barrella, 814 F.3d 594 (2d Cir. 2016) (favoritism/nepotism not unlawful absent protected-class animus)
Belfi v. Prendergast, 191 F.3d 129 (2d Cir. 1999) (prima facie elements for pay discrimination)
Woodman v. WWOR-TV, Inc., 411 F.3d 69 (2d Cir. 2005) (conclusory allegations insufficient to defeat summary judgment)
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (U.S. 1986) (standard for granting summary judgment)