Ayiesha Wright filed a lawsuit against White Plains Hospital Medical Center in September 2019, alleging that her employment was terminated in January 2019 due to her pregnancy. Wright had been hired as a phlebotomist in August 2018, subject to a six-month probationary period. She asserted that her dismissal violated Title VII of the Civil Rights Act of 1964 and the New York State Human Rights Law (NYSHRL).
The amended complaint, filed in November 2019, claimed that the termination constituted gender discrimination, as discrimination on the basis of pregnancy is treated as a form of gender discrimination under both statutes. The hospital moved for summary judgment, seeking dismissal of the amended complaint.
Legal standards and court review
The NYSHRL was amended in 2019 to align more closely with the New York City Human Rights Law (NYCHRL), requiring that employment decisions be free of any discriminatory motivation. The court applied both the McDonnell Douglas burden-shifting framework and the mixed-motive framework to analyze the summary judgment motion.
Under the McDonnell Douglas framework, a defendant must provide a legitimate, nondiscriminatory reason for the employment action once the plaintiff makes a prima facie case. Under the mixed-motive standard, the defendant must show there is no evidentiary path by which a jury could find that discrimination played any role in the decision.
White Plains Hospital submitted evidence that there was no route for a jury to find that pregnancy discrimination was a motivating factor in Wright’s termination. Wright, in response, failed to raise a triable issue of fact. The court found that she had not provided evidence that the hospital's stated reasons for her dismissal were pretextual or that discrimination had played a role. Her claims were deemed speculative and insufficient to overcome summary judgment.
Final ruling
The Supreme Court granted summary judgment in favor of White Plains Hospital. The Appellate Division, Second Department, affirmed that ruling, holding that Wright had not presented sufficient evidence to support her pregnancy discrimination claims under the NYSHRL or Title VII.
Help with employment discrimination claims
If you’ve experienced discrimination, harassment, or retaliation at work, Whitcomb, Selinsky PC handles cases involving wrongful termination, hostile work environments, and other unlawful treatment. Reach out to schedule a consultation and learn how our team can assist with your claim.
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