Khademi v. AANIKA Biosciences, Inc., 1:24-cv-05130

Plaintiff Farshad Khademi, an experienced scientist, worked for AANIKA Biosciences, Inc. as a lead fermentation scientist from January to August 2022 in Brooklyn, NY.
Plaintiff alleges he was ordered by supervisors (Bhuyan and Jorgensen) to move a heavy machine, resulting in injury and disability.
After reporting his injuries and seeking accommodations for medical treatment, plaintiff claims he was warned about absences, ultimately terminated by Bhuyan soon after requesting more accommodations.
The First Amended Complaint alleged disability and sex discrimination, retaliation, and failures under the ADA, NYSHRL, and NYCHRL against AANIKA, Bhuyan, and Jorgensen.
Defendants moved to dismiss all claims for failure to state a claim; court considered allegations as true for purposes of the motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
ADA Disability Discrimination	Terminated because of disability and related absences.	Termination not due to disability, no discriminatory animus.	Denied dismissal; facts plausibly show disability as but-for cause.
ADA Retaliation	Termination was in retaliation for requests for accommodation.	No protected activity; no causal connection to termination.	Denied dismissal; requests were protected, close temporal proximity.
NYSHRL Disability Discrimination – Individual Liability	Bhuyan and Jorgensen aided discrimination by their conduct.	No individual liability; no participation in adverse actions.	Bhuyan: Denied dismissal; Jorgensen: Dismissed claim.
NYSHRL/NYCHRL Sex Discrimination	Asked to move machinery because of male gender.	No facts showing discriminatory intent, just one isolated incident.	Dismissed; allegations insufficient to suggest discrimination.
NYSHRL/NYCHRL Retaliation	Multiple protected activities led to retaliation.	No applicable protected activity under state law.	Dismissed; activities not protected under NYSHRL.
NYCHRL Failure to Engage in Interactive Process	No cooperative dialogue on accommodation request.	No separate cause of action for process failures.	Dismissed as no independent claim exists.
NYCHRL Disability Discrimination / Retaliation	Terminated/treated less well due to disability.	No causal nexus or discriminatory intent.	Denied dismissal as to AANIKA and Bhuyan; dismissed as to Jorgensen.

Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard for plausibility on a motion to dismiss)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading must state claim plausible on its face)
Littlejohn v. City of New York, 795 F.3d 297 (NYSHRL aiding and abetting standard; minimum inference at pleading stage)
Vega v. Hempstead Union Free Sch. Dist., 801 F.3d 72 (pleading discrimination claims in the Second Circuit)
Feingold v. New York, 366 F.3d 138 (individual liability under NYSHRL for actual participation in discrimination)
Swierkiewicz v. Sorema N.A., 534 U.S. 506 (prima facie case not necessary at pleading stage)
Kinneary v. City of New York, 601 F.3d 151 (elements for NYCHRL disability discrimination claim)