Meckeler v. Cornell University
3:23-cv-00773
| N.D.N.Y. | Jul 25, 2024Background
- Amy Meckeler, an openly gay female, was employed as Assistant Dean for Communications at Cornell University’s College of Human Ecology from 2016-2022.
- Defendant Rachel Dunifon became her direct supervisor in 2018 and, according to Meckeler, behavior toward her changed after the onset of the COVID-19 pandemic.
- Meckeler alleges she was consistently overworked, denied the chance to hire necessary staff, and began experiencing exclusion and negative feedback she attributes to discriminatory bias regarding her sexual orientation.
- After raising concerns of sex/gender and sexual orientation discrimination with Cornell’s Title IX office, Meckeler received a negative performance evaluation, lost supervisory duties, was removed from a critical project, placed on a different assignment, and then terminated.
- She filed suit against Cornell University, the College of Human Ecology, and Dunifon under Title VII and the NYSHRL, claiming sex/gender discrimination, hostile work environment, and retaliation.
- Defendants moved to dismiss the complaint under Rule 12(b)(6) for failure to state a claim.
Issues
| Issue | Plaintiff’s Argument | Defendant’s Argument | Held |
|---|---|---|---|
| Individual liability under Title VII | Title VII claims apply to Dunifon | No individual liability under Title VII | Dismissed with prejudice |
| Discrimination/Hostile work environment | Actions/mistreatment due to sexual orientation | No facts to plausibly show discriminatory intent | Dismissed without prejudice |
| Retaliation for protected activity | Termination/reprisal closely followed Title IX complaint | No temporal proximity or factual specifics | Dismissed without prejudice |
| Leave to amend | Request to amend to cure deficiencies/add claims | Plaintiff failed to follow amendment procedures | Denied (but may move for leave to amend) |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (standard for plausibility in pleadings)
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standards for motions to dismiss)
- Littlejohn v. City of New York, 795 F.3d 297 (minimal inference of discriminatory motivation in Title VII claims)
- Bostock v. Clayton County, 590 U.S. 644 (sexual orientation discrimination is sex discrimination under Title VII)
- Harris v. Forklift Sys., Inc., 510 U.S. 17 (hostile work environment under Title VII)
- Feingold v. New York, 366 F.3d 138 (hostile work environment must be related to protected characteristic)