Meyer v. New York State Office of Mental Health
679 F. App'x 89
2d Cir.2017Background
- Plaintiff Jill Meyer, M.D., a former psychiatrist, sued NY State Office of Mental Health, Creedmoor Psychiatric Center, and Dr. Caterina Grandi under Title VII for gender and religious (Jewish) discrimination after not being rehired following a 2011 interview.
- District Court (E.D.N.Y.) granted summary judgment for defendants on Meyer’s Title VII claims and dismissed her state-law claims without prejudice.
- Meyer relied on statements she felt showed discrimination, a comment by Grandi referencing Meyer’s Jewish background during the interview, deviations in interview practice (Grandi extended an interview), and the composition of Creedmoor’s staff.
- Defendants presented legitimate, nondiscriminatory reasons: more-qualified hires filled the positions and documented prior performance problems while Meyer worked at Creedmoor (disorganization, missed appointments, untimely paperwork).
- The Second Circuit reviewed de novo the grant of summary judgment and the district court’s discretionary decision to decline supplemental jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Meyer established a prima facie case of gender discrimination under Title VII | Meyer contends she was treated differently due to gender, relying on her impressions and interview experience | Defendants argue Meyer offered only conclusory assertions and no evidence suggesting gender-based animus | Court: Meyer failed to show circumstances giving rise to inference of gender discrimination; summary judgment affirmed |
| Whether defendants’ nondiscriminatory reasons were pretext for gender discrimination | Meyer argues adverse action was discriminatory despite stated reasons | Defendants proffered legitimate reasons: more-qualified hires and prior documented performance issues | Court: Even assuming prima facie case, Meyer did not show pretext; reasons were legitimate |
| Whether Meyer proved religious (Jewish) discrimination under Title VII | Meyer points to Grandi’s passing remark about her Jewish family, deviation in interview practices, and alleged workplace anti-Semitic “flavor” | Defendants say remarks and procedural deviations do not show animus; hires were better qualified | Court: The single vague comment and other evidence were insufficient to prove discriminatory motive; summary judgment affirmed |
| Whether district court abused discretion by declining supplemental jurisdiction over state-law claims | Meyer presumably wanted federal court to retain state claims after Title VII dismissal | Defendants argue dismissal of federal claims negated basis for supplemental jurisdiction | Court: No abuse of discretion; dismissal without prejudice was appropriate |
Key Cases Cited
- Halo v. Yale Health Plan, Dir. of Benefits & Records Yale Univ., 819 F.3d 42 (2d Cir. 2016) (standard for reviewing summary judgment in employment cases)
- Walsh v. N.Y.C. Hous. Auth., 828 F.3d 70 (2d Cir. 2016) (McDonnell Douglas framework for Title VII and NYHRL claims)
- Weinstock v. Columbia Univ., 224 F.3d 33 (2d Cir. 2000) (elements of prima facie case under McDonnell Douglas)
- Vega v. Hempstead Union Free Sch. Dist., 801 F.3d 72 (2d Cir. 2015) (plaintiff’s burden to show employer’s explanation is pretextual)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden-shifting framework for discrimination claims)
- Shumway v. United Parcel Serv., Inc., 118 F.3d 60 (2d Cir. 1997) (requirements for showing similarly situated comparators and pretext)
- Gregory v. Daly, 243 F.3d 687 (2d Cir. 2001) (employer’s dissatisfaction with performance can be legitimate nondiscriminatory reason)
- Woodman v. WWOR-TV, Inc., 411 F.3d 69 (2d Cir. 2005) (conclusory allegations insufficient to defeat summary judgment)
- Stern v. Trs. of Columbia Univ., 131 F.3d 305 (2d Cir. 1997) (deviations from normal hiring practices may be evidence of discrimination)
- Carlsbad Tech., Inc. v. HIF Bio, Inc., 556 U.S. 635 (2009) (standard for review of discretionary supplemental jurisdiction decisions)
- Pension Benefit Guar. Corp. v. Morgan Stanley Inv. Mgmt. Inc., 712 F.3d 705 (2d Cir. 2013) (factors for exercising supplemental jurisdiction)