Roddey v. KPMG L.L.P.
1:22-cv-07405
S.D.N.Y.Apr 14, 2025Background
- Coretta Roddey, an African American woman, was hired by KPMG for a New York-based role but worked remotely from Georgia due to Covid-19 protocols.
- Her offer required relocating to New York by a specified date; she remained in Georgia but planned to move.
- Roddey alleged discrimination and retaliation during her employment, claiming she was denied opportunities and ultimately terminated for rejecting projects, which she argued was pretext for discrimination.
- She filed claims under Title VII, 42 U.S.C. § 1981, the New York State Human Rights Law (NYSHRL), and the New York City Human Rights Law (NYCHRL) against KPMG and various individual supervisors.
- Defendants moved to dismiss the claims against individual defendants for lack of personal jurisdiction and sought summary judgment on the NYCHRL and NYSHRL claims, arguing no sufficient New York impact.
- The court’s opinion primarily addresses jurisdiction over the individual defendants and the "impact" requirement for the state and city law claims in light of recent case law developments.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Personal jurisdiction over individuals | Individuals managed Roddey (a NY-assigned employee); jurisdiction exists under NY's long-arm statute | Individuals neither lived nor worked in NY; all acts centered in GA | No specific jurisdiction; acts did not occur in NY and Roddey never worked from NY |
| Jurisdictional discovery/amendment request | Seeks leave to take jurisdictional discovery and amend complaint | No threshold showing to justify either; amendment would be futile | Discovery denied absent facts supporting jurisdiction; amendment denied without specifics |
| NYCHRL/NYSHRL "impact" requirement | Suffered actionable impact in NY by being denied NY job opportunity | All relevant acts' impact experienced in GA, not NY | Under Syeed, impact in NY exists when termination denies chance to work in NY |
| Dismissal or summary judgment (NYCHRL/NYSHRL claims) | KPMG’s actions sufficiently affected her anticipated employment in NY | Insufficient NY impact to state a claim as required by law | Dismissal and summary judgment denied for claims against KPMG; claims may proceed |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (articulates plausibility standard for Rule 12(b)(6) motions)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (establishes pleading standard for survival of motion to dismiss)
- Hoffman v. Parade Publ’ns, 933 N.E.2d 744 (N.Y. 2010) (sets out "impact in NY" requirement for state/city HRL claims)
- McGowan v. Smith, 419 N.E.2d 321 (N.Y. 1981) (addresses New York’s long-arm statute for personal jurisdiction)
- Spectrum Dynamics Med. Ltd. v. Gen. Elec. Co., 2023 WL 4159358 (S.D.N.Y. 2023) (prima facie showing for jurisdiction) [Note: No official reporter, so not included]
- Syeed v. Bloomberg L.P., 235 N.E.3d 351 (N.Y. 2024) (clarifies "impact" test applies to nonresident plaintiffs denied NY jobs)