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SANDERS v. CITY OF NEW YORK

May 15, 2002

EVELYN C. SANDERS, PLAINTIFF,
V.
THE CITY OF NEW YORK, DEFENDANT.



The opinion of the court was delivered by: Marrero, District Judge.

DECISION AND ORDER

INTRODUCTION

This matter came before the Court for a trial by jury from May 6, 2002 until May 10, 2002, when the jury returned verdicts in favor of defendant, the City of New York (the "City"), on all of plaintiffs claims.

At the close of evidence, plaintiff Evelyn C. Sanders ("Sanders") withdrew her claims against former Commissioner Jason A. Turner, New York City Human Resources Administration ("HRA"), leaving the City as the only remaining defendant. However, at the first of two conferences the Court held with the parties relating to the jury instructions, Sanders sought to add a separate claim for disparate treatment discrimination pursuant to Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e, et seq. ("Title VII"), notwithstanding the fact that Sanders had not submitted a separate charge for that claim in her proposed jury instructions. Nevertheless, the Court agreed that viewing all of the allegations in the second amended complaint as a whole, which was filed pro se, a separate charge for the disparate treatment discrimination claim was warranted under the circumstances. Thus, the Court permitted Sanders to put three claims before the jury: discrimination in the terms and conditions of employment, unlawful retaliation, and disparate treatment discrimination all brought pursuant to Title VII.

Upon the conclusion of their respective cases-in-chief, the parties cross-moved for judgment as a matter of law pursuant to Rule 50(a) of the Federal Rules of Civil Procedure. The City's motion for judgment as a matter of law is now moot. The jury returned verdicts in favor of the City on all claims. However, when the motions were made, the Court reserved judgment, permitting the jury to deliberate on all of Sanders's claims. Presently before the Court is Sanders's motion for judgment as a matter of law on all of her claims, which, as a technical matter, remains pending although the jury returned verdicts against her on all those claims.

STANDARD OF REVIEW

Rule 50 of the Federal Rules of Civil Procedure allows a party to move for judgment as a matter of law at any time before the case has been submitted to the jury. Wimmer v. Suffolk County Police Dep't, 176 F.3d 125, 134 (2d Cir. 1999). A court may grant a motion for judgment as a matter of law if there is no legally sufficient evidentiary basis to support the nonmoving party's claim or defense. Id.; Fed.R.Civ.P. 50(a). In assessing the merits of a Rule 50(a) motion, courts must view the evidence in the light most favorable to the non-moving party — in this case, the City — and draw all reasonable inferences in its favor. Wimmer, 176 F.3d at 134.

DISCUSSION

Applying the relevant standard of review here, the Court finds that any reasonable jury could have concluded that, as a threshold matter, Sanders failed to establish a prima facie case for any of her claims under Title VII. In addition, any reasonable jury could have been persuaded by the overwhelming evidence that the allegedly unlawful actions on the part of the City were taken for legitimate, nondiscriminatory reasons. Therefore, Sanders's motion for judgment as a matter of law is denied in its entirety.

All of Sanders's claims, although conceptually distinct, are grounded in Title VII. As such, all of Sanders's claims require a showing of the same core elements as set forth in McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802, 93 S.Ct. 1817, 36 L.Ed.2d 668 (1973). In view of the plaintiffs claims and the specific circumstances present there, the Supreme Court held in McDonnell Douglas that

[t]he complainant in a Title VII trial must, carry the initial burden under the statute of establishing a prima facie case of racial discrimination. This may be done by showing (i) that he belongs to racial minority; (ii) that he applied and was qualified for a job for which the employer was seeking applicants; (iii) that, despite his qualifications, he was rejected; and (iv) that, after his rejection, the position remained open and the employer continued to seek applicants from persons of complainant's qualifications.

McDonnell Douglas, 411 U.S. at 802, 93 S.Ct. 1817. Assuming that a complainant establishes a prima facie case of discrimination, the burden then shifts to the employer to articulate a legitimate, non-discriminatory reason for its actions. Id.; see also St. Mary's Honor Center v. Hicks, 509 U.S. 502, 506-07, 113 S.Ct. 2742, 125 L.Ed.2d 407 (1993).

The elements set forth above are not a rigid, unyielding standard. Every action pursuant to Title VII will differ materially in the specific acts complained of, the type and severity of the unlawful actions alleged and the specific kinds of harm cognizable under the statute. Nevertheless, McDonnell Douglas delineated a baseline formulation which has become the starting point for actions pursuant to Title VII. The Court addresses all of Sanders's claims separately below, but the common thread in the analyses is the Court's finding ...


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