Gehlaut v. New York City Department of Education, 1:22-cv-07862

Plaintiff Dharmvir Gehlaut, of Indian national origin and Hindu faith, was employed as a math teacher by the New York City Department of Education (DOE) at Baccalaureate School for Global Education (BSGE) beginning in 2017.
Gehlaut alleged discrimination and retaliation based on his reassignment to a "Rubber Room" (where he did not teach classes) and being subjected to disciplinary proceedings, following alleged discriminatory comments by Principal Kelly Johnson.
Key factual allegations included verbal insults regarding national origin and English skills, an allegedly discriminatory remark by Johnson, and job reassignment in 2019 and 2020.
Plaintiff dual-filed discrimination charges with the New York State Division of Human Rights (NYSDHR) and the EEOC in July 2020 and again in April 2022; disciplinary proceedings began in 2018 and concluded in a three-month suspension in 2022.
Plaintiff brought federal claims under Title VII, as well as state and city claims under the NYSHRL and NYCHRL, against the DOE and Johnson. Defendants moved to dismiss, arguing lack of notice, untimeliness, and failure to state a claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are pre-September 24, 2019 Title VII claims time-barred?	Claims relate to continuing violation and hostile work environment.	Acts before 300-day EEOC filing window are time-barred.	Claims before deadline are time-barred and dismissed.
Did reassignment and disciplinary actions constitute discrimination?	Reassignment and discipline stemmed from discriminatory animus evidenced by remarks.	No plausible facts connect remarks to job actions; decisionmakers differed.	No inference of discrimination; dismissed under Rule 12(b)(6).
Retaliation claim under Title VII based on § 3020-a proceedings	Proceeds against him were in retaliation for EEOC charge.	Proceedings began before protected activity; no causal connection.	Retaliation claim dismissed—no causal nexus or temporal proximity.
State-law claims: Adequacy of notice and statute of limitations	EEOC filing suffices for notice; claims are timely.	No proper notice to DOE as required by NY Ed. Law § 3813(1); many claims untimely.	State and city claims dismissed for lack of notice and/or timeliness.

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading standard for plausibility in federal court)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (factual plausibility standard for complaints)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden-shifting framework in Title VII discrimination cases)
Legnani v. Alitalia Linee Aeree Italiane, S.P.A., 274 F.3d 683 (2d Cir. 2001) (exhaustion of administrative remedies is essential for Title VII claims)
Sanders v. N.Y.C. Human Res. Admin., 361 F.3d 749 (2d Cir. 2004) (defines adverse employment action)
Danzer v. Norden Sys., Inc., 151 F.3d 50 (2d Cir. 1998) (stray remarks insufficient for discrimination claims)