Magnani v. North Shore Central School District, 2:16-cv-02519

Plaintiff Linda Magnani, born 1955, was a 2014–15 leave-replacement/probationary sixth-grade math teacher at North Shore Middle School who resigned mid-December 2014 after being told the District would recommend her midyear termination to the Board.
School administrators (Principal Marc Ferris, teacher leader Amy Dimeola, and assistant principal Rachel Green) observed and criticized Magnani’s classroom performance and engagement; Ferris recommended termination to the superintendent.
Magnani resigned before the Board vote to avoid a midyear termination on her record; she says she resigned under the choice of resign or be terminated and that the termination would harm future employment.
Magnani sues the District under the ADEA (age discrimination), sues Ferris under the NYSHRL (personal liability), and brings an Equal Protection claim under 42 U.S.C. § 1983; defendants moved for summary judgment.
The District defended on grounds of legitimate, nondiscriminatory reasons (poor teaching/student engagement), denied an adverse action, asserted no inference of age bias, and argued Ferris lacked individual liability/was entitled to qualified immunity for § 1983.
The district court denied summary judgment, finding triable issues on constructive discharge/adverse action, inference of age discrimination (younger replacements), pretext, Ferris’s personal liability under NYSHRL, and that the § 1983 claim was not preempted by the ADEA.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Magnani suffered an adverse employment action (constructive discharge)	She resigned to avoid a midyear termination that would stigmatize future employment; resignation was coerced	No constructive discharge because alternatives (e.g., submitting a letter to the board) existed	Triable issue exists; summary judgment denied on adverse action question
Whether circumstances give rise to an inference of age discrimination	Replacements were substantially younger (≈15–25 years), supporting an inference	Hiring age and plaintiff’s being within protected class when hired weakens inference	Jury could infer discrimination; prima facie case survives summary judgment
Whether District’s proffered reason (poor teaching/student engagement) is pretextual	Evidence shows evaluators changed views after conferring, suggesting manufactured complaints	Stated dissatisfaction with teaching is a legitimate nondiscriminatory reason for termination	Triable issue on pretext; summary judgment denied
Whether Ferris is personally liable and entitled to qualified immunity for § 1983	Ferris participated in conduct leading to resignation; discriminating on basis of age would violate clearly established rights	Ferris argues no liability under NYSHRL and qualified immunity on § 1983	Ferris may be personally liable under NYSHRL if jury finds discrimination; qualified immunity not warranted if jury finds constitutional violation; § 1983 not preempted by ADEA

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (establishing burden-shifting framework for discrimination claims)
O'Connor v. Consol. Coin Caterers Corp., 517 U.S. 308 (replacement substantially younger can give rise to inference of age discrimination)
Bucalo v. Shelter Island Union Free Sch. Dist., 691 F.3d 119 (ADEA claims governed by McDonnell Douglas framework)
Carlton v. Mystic Transp., Inc., 202 F.3d 129 (plaintiff may rely on prima facie evidence and inferences to show pretext)
Lopez v. S.B. Thomas, Inc., 831 F.2d 1184 (constructive discharge can include being given a choice to resign or be fired)
Tomka v. Seiler Corp., 66 F.3d 1295 (individuals who participate in discriminatory conduct may be personally liable under NY law)
Pearson v. Callahan, 555 U.S. 223 (qualified immunity framework)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (standard for genuine issue of material fact at summary judgment)