Rojas v. Roman Catholic Diocese of Rochester
2011 U.S. App. LEXIS 20125
| 2d Cir. | 2011Background
- Rojas was employed by the Diocese as Coordinator for Hispanic Migrant Ministry for the Brockport Area from May 2, 2004, to November 9, 2006, supervised by Bernard Grizard in Parish Support Ministries.
- Her office was on Church of the Nativity’s campus in Brockport; the Church of the Nativity is a separate entity from the Diocese, with Enyan-Boadu as pastor (employed by the Church, not the Diocese).
- Rojas alleged sexual harassment by Enyan-Boadu creating a hostile work environment and that the Diocese fired her in retaliation for complaining about him.
- A key issue was whether Enyan-Boadu’s harassment could be imputed to the Diocese, requiring supervisor status and the Diocese’s knowledge of the harassment; evidence primarily consisted of Rojas’s own statements and testimony, which conflicted with other sworn statements and a criminal trial resulting in acquittal for Enyan-Boadu.
- The District Court granted summary judgment, finding Rojas’s testimony inconsistent and not credible, and dismissed Title VII/NYSHRL claims while declining supplemental jurisdiction over an assault-and-battery claim; on appeal, the court affirmed, limiting its review to the District Court’s handling of the alleged contradictions.
- The appeal does not challenge the dismissal of the common law assault-and-battery claim, which remained separate.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the District Court properly disregarded Rojas’s contradictory testimony in ruling on summary judgment. | Rojas argues credible disputes exist; the court should not weigh credibility at summary judgment. | The District Court properly assessed contradictory, material facts and disregarded implausible assertions. | Yes; the court may pierce pleadings’ contradictions and grant summary judgment where testimony is inconsistent. |
| Whether Enyan-Boadu’s harassment could be imputed to the Diocese under Title VII. | If Enyan-Boadu was a supervisor or if the Diocese knew and failed to act, liability attaches. | Enyan-Boadu was not a Diocese supervisor and the Diocese had no notice of harassment; it provided a complaint mechanism. | No; the Diocese could not be held liable for harassment by Enyan-Boadu given supervisory status and lack of notice evidence. |
| Whether Rojas established a prima facie case of retaliation under Title VII. | Rojas engaged in protected activity and was retaliated against. | Any complaints were generalized and not clearly protected activity under Title VII; termination was pretextual or non-retaliatory. | No; the record showed generalized complaints and a legitimate, nonretaliatory reason for termination, failing prima facie case. |
| Whether the hostile environment and retaliation claims were properly dismissed under the NYSHRL and Title VII. | Claims should go to a jury based on conflicting evidence. | District Court properly dismissed due to lack of imputed liability and absence of protected activity evidence. | Yes; the claims were properly dismissed. |
| Whether the court’s handling of Rojas’s evidentiary submissions complied with governing standards. | Evidentiary rulings should not excessively weigh credibility. | In extraordinary cases, such as this, the court may assess inconsistent testimony to determine genuine issues. | Yes; the district court’s evidentiary rulings were proper under controlling precedents. |
Key Cases Cited
- Anderson v. Liberty Lobby, Inc., 477 F.2d 242 (Supreme Court 1986) (established standard for genuine issues of material fact in summary judgment)
- Jeffreys v. City of New York, 426 F.3d 549 (2d Cir. 2005) (exception to credibility preservation when plaintiff relies almost exclusively on own contradictory testimony)
- Galdieri-Ambrosini v. National Realty & Dev. Corp., 136 F.3d 276 (2d Cir. 1998) (knowledge/awareness requirement for employer liability for harassment)
- Perry v. Ethan Allen, Inc., 115 F.3d 143 (2d Cir. 1997) (employer liability when no adequate complaint procedure or known harassment; supervisor/authority)
- Mack v. Otis Elevator Co., 326 F.3d 116 (2d Cir. 2003) (test for hostile work environment claims; supervisor liability considerations)