Claudia Lefort began working for Kingsbrook Jewish Medical Center in 2006 as a community access coordinator (CAC). In December 2012, she requested and was approved for maternity leave. During her leave, she began reporting to a new supervisor, Delicia Segree, who allegedly made disparaging remarks about Lefort’s pregnancy and upcoming maternity leave. On June 25, 2013, the day she returned to work, Lefort was informed that her position had been eliminated due to a departmental reorganization.
Lefort subsequently filed suit in the Supreme Court of New York, Kings County, alleging gender and pregnancy discrimination under the New York State Human Rights Law (NYSHRL) and the New York City Human Rights Law (NYCHRL). She asserted that her termination was motivated by discriminatory bias against pregnant employees. Kingsbrook Jewish Medical Center moved for summary judgment, claiming that Lefort’s position was legitimately eliminated and replaced with a new role requiring additional marketing experience.
The Supreme Court granted summary judgment to Kingsbrook, finding that the hospital had articulated a legitimate, nondiscriminatory reason for the termination. The court accepted the hospital’s explanation that Lefort’s CAC position was restructured into a community relations manager (CRM) position requiring business education and sales experience, which Lefort allegedly lacked. Lefort appealed the decision to the Appellate Division, Second Department.
The Appellate Division reversed the lower court’s ruling, holding that genuine issues of material fact existed regarding whether Kingsbrook’s stated reasons for termination were a pretext for discrimination. The appellate court noted that pregnancy discrimination is a form of gender discrimination under both the NYSHRL and NYCHRL.
The court found that Lefort established a prima facie case of discrimination by demonstrating that she was a member of a protected class, qualified for her position, suffered an adverse employment action, and that the circumstances suggested discriminatory intent. Kingsbrook argued that Lefort was not subjected to an adverse action because it had offered her a temporary social worker position at the same salary shortly after her termination. However, the court determined that this position lacked the management responsibilities of her previous role, representing a material adverse change in the conditions of employment.
The appellate court also found that there were triable issues as to whether Segree made remarks indicative of discriminatory motive and whether she participated in the termination decision. Evidence in the record showed that Segree attended the meeting where Lefort’s termination was discussed, contradicting the hospital’s claim that she had no involvement.
The court further noted that Kingsbrook’s stated justification—that Lefort lacked business education and marketing experience—was undermined by its own evidence. Lefort’s 2012 performance evaluation indicated that she had successfully carried out marketing-related duties. Additionally, a 2014 letter from Kingsbrook offered Lefort the CRM position, describing it as “virtually identical” to her previous CAC role. This letter suggested that the two positions were substantially the same and that the earlier termination may not have been based on legitimate business needs.
Under the NYCHRL, the court reiterated that discrimination must play “no role” in employment decisions and that the statute should be construed liberally in favor of employees. Kingsbrook failed to demonstrate the absence of an evidentiary route by which a jury could find that discrimination influenced the termination.
On March 2, 2022, the Appellate Division reversed the Supreme Court’s decision and reinstated Lefort’s claims of gender and pregnancy discrimination against Kingsbrook Jewish Medical Center. The case was remanded for further proceedings.
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