Samuel Padilla v. Yeshiva University
691 F. App'x 53
| 2d Cir. | 2017Background
- Plaintiffs Samuel Padilla and Dominic Amato were terminated by Yeshiva University after taking or seeking FMLA leave and prior use of FMLA rights.
- Plaintiffs filed suit alleging FMLA retaliation and disability discrimination under the New York City Human Rights Law (NYCHRL).
- The district court granted a Rule 12(b)(6) dismissal and denied Plaintiffs’ request for leave to amend the complaint a second time, finding their pleadings implausible.
- Plaintiffs appealed the dismissal and the denial of leave to amend.
- The Second Circuit reviewed the pleadings de novo and considered whether the complaint plausibly alleged retaliation under the FMLA and disability discrimination under the NYCHRL.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| FMLA retaliation — plausibility | Plaintiffs alleged a causal link: timing, inconsistent reasons for termination, and prior hostility after exercising FMLA. | Yeshiva argued Plaintiffs failed to plausibly link FMLA leave to termination. | Reversed — allegations (timing, inconsistent explanations, prior hostility) suffice at pleading stage to infer retaliation. |
| NYCHRL disability discrimination — plausibility | Same facts supporting retaliation also show termination was caused at least in part by discriminatory/retaliatory motives. | Yeshiva contended pleadings did not plausibly allege discrimination. | Reversed — NYCHRL is broader; complaint plausibly alleged discriminatory motive. |
| Denial of leave to amend (futility) | Plaintiffs sought another chance to amend the complaint to cure defects. | District court found further amendment would be futile. | Reversed — because dismissal of the claims was erroneous, the futility determination was incorrect and remand is required. |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (plausibility standard for federal pleadings)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading must raise claim above speculative level)
- Harris v. Mills, 572 F.3d 66 (de novo review of Rule 12(b)(6) dismissal)
- Boykin v. KeyCorp, 521 F.3d 202 (retaliation/discrimination need not plead prima facie case at motion to dismiss)
- Starr v. Sony BMG Music Entm’t, 592 F.3d 314 (pleading standards and reasonable inferences)
- Panther Partners Inc. v. Ikanos Commcn’s, Inc., 681 F.3d 114 (de novo review of denial of leave to amend when based on legal interpretation)
- Mihalik v. Credit Agricole Cheuvreux N. Am., Inc., 715 F.3d 102 (NYCHRL construed broadly; causation standard 'at least in part')