Williams v. Time Warner Inc.
440 F. App'x 7
2d Cir.2011Background
- Williams, African American female, was hired as VP of Diversity and Multicultural Initiatives at Time Warner in 2007.
- She allegedly complained about management’s stereotyping of her as an “angry black woman.”
- Six days after her complaint, Williams was fired in November 2007.
- She sued Time Warner and Lisa Quiroz alleging Title VII discrimination and retaliation.
- The district court dismissed her complaint under Rule 12(b)(6) for failure to state a claim.
- The Second Circuit reviews de novo and affirms dismissal on both discrimination and retaliation claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether discrimination claim was plausibly stated. | Williams alleges race/gender–based discrimination from the comment. | Defendants contend the comment lacks racial sub-text and not plausibly discriminatory. | Discrimination claim dismissed for lack of plausible causation. |
| Whether retaliation claim was plausibly stated. | Williams asserts a causal link between protected activity and adverse action. | Defendants argue insufficient evidence of causation or reasonable belief. | Retaliation claim dismissed; no plausible causal connection shown. |
Key Cases Cited
- Taylor v. Vermont Dep't of Educ., 313 F.3d 768 (2d Cir. 2002) (documents incorporated by reference may be considered in Rule 12(b)(6) context)
- Roth v. Jennings, 489 F.3d 499 (2d Cir. 2007) (de novo review of Rule 12(b)(6) dismissal)
- Sira v. Morton, 380 F.3d 57 (2d Cir. 2004) (outside materials not incorporated unless integral to complaint)
- Cosmas v. Hassett, 886 F.2d 8 (2d Cir. 1989) (outside materials not incorporated unless integral to complaint)
- Chambers v. Time Warner, Inc., 282 F.3d 147 (2d Cir. 2002) (outside materials not sufficiently integrated into complaint)
- Patane v. Clark, 508 F.3d 106 (2d Cir. 2007) (causal connection required in discrimination claims)
- Leibovitz v. N.Y. City Transit Auth., 252 F.3d 179 (2d Cir. 2001) (causal connection standard for discrimination claims)
- Manoharan v. Columbia Univ. Coll. of Physicians & Surgeons, 842 F.2d 590 (2d Cir. 1988) (good-faith belief required for retaliation claims)
- Gorzynski v. JetBlue Airways Corp., 596 F.3d 93 (2d Cir. 2010) (some causation evidence may establish prima facie case)
- Ashcroft v. Iqbal, 129 S. Ct. 1937 (Supreme Court 2009) (standard: pleading must show more than a sheer possibility)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (Supreme Court 2007) (pleading requires plausible entitlement to relief)