Harlow v. Molina Healthcare, Inc.
723 F. Supp. 3d 116
N.D.N.Y.2024Background
- Christi A. Harlow, an African-American woman, was employed by Molina Healthcare, Inc. as a coding analyst for five months before being terminated.
- Harlow filed an eleven-count complaint alleging race discrimination, sex discrimination (hostile work environment), and retaliation, under Title VII, NYSHRL, and § 1981 (pay disparity and termination).
- Plaintiff withdrew her gender-based and part of her race-based pay discrimination claims, leaving only pay disparity claims based on comparison with her (white) former supervisor, Jennifer Hendrix.
- Harlow reported sexual harassment by a co-worker (Susan Browne) and, soon after, received both a positive performance review and a disciplinary notice, which was followed by her termination.
- Plaintiff alleged that employer representatives (notably, supervisor Luke Gozzi) used racially stereotyped terms about her and that Molina manufactured reasons to justify her firing after her harassment complaint.
- Molina moved for summary judgment on all claims; the court considered the parties’ briefs and ruled on the motion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Race Discrimination - Termination | Harlow argues her termination was motivated by racial bias and pretext. | Molina cites unacceptable behavior/poor performance as legitimate reason. | Denied summary judgment: triable issue. |
| Race Discrimination - Disparate Pay | Harlow claims she was paid less than similarly situated white employee. | Hendrix had more/different responsibilities, no race-based pay decision. | Granted summary judgment: insufficient evidence of racial animus. |
| Sex Discrimination - Hostile Work Envt | Browne’s conduct (touching, comments) created abusive environment based on sex. | Browne’s conduct not severe/pervasive; not clearly motivated by sex. | Denied summary judgment: triable issues. |
| Retaliation | Termination was direct result of complaining about sexual harassment. | Termination was for performance reasons, not retaliation. | Denied summary judgment: triable issues. |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (establishes burden-shifting framework for discrimination cases)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard – genuine dispute of material fact)
- Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (prima facie case plus pretext may permit finding of discrimination)
- Meritor Sav. Bank, FSB v. Vinson, 477 U.S. 57 (standard for hostile work environment claims)
- Oncale v. Sundowner Offshore Servs., Inc., 523 U.S. 75 (same-sex harassment actionable if motivated by sex)