A former human resources employee failed to prove that the Trustees of St. Patrick’s Cathedral discriminated against her, a federal judge ruled in a case against the trustees and the Archdiocese of New York. Judge Paul Engelmayer of the U.S. District Court for the Southern District of New York granted summary judgment to the defendants on all claims.
The trustees were restructuring their HR operations by moving them to the archdiocese. They told the employee that her position would be eliminated and offered her a job in the archdiocese’s HR department. According to court documents, she did not respond by the deadline, and her position was eliminated.
The former employee alleged race, national origin, sex and age discrimination, as well as retaliation and intentional infliction of emotional distress. The judge found no evidence that the defendants had made comments about her age, race or gender, or linked any decision to those characteristics. The employee also confirmed in her deposition that no such comments had been made.
She said a Hispanic colleague who had resigned believed the trustees’ executive director disliked her because she was Hispanic. Engelmayer deemed that account hearsay and noted that the employee offered no other evidence of bias or harassment during her employment.
The employee also argued that White male staff whose roles were eliminated received severance, while she did not. The trustees said she was not offered severance because she had already received an offer to work for the archdiocese. The judge noted that the employees she cited held different positions and that she had not shown they were otherwise similarly situated.
The court accepted the trustees’ explanation that the position was eliminated as part of broader structural changes and that they lacked confidence in the employee’s ability to meet their HR needs. The defendants said she was insufficiently familiar with their policies, relied unreasonably on outside counsel and produced written work that often contained errors. They also cited concerns about her ability to identify legal risks in the workplace. The court said she had not presented evidence to rebut those claims and concluded she failed to meet the initial burden of showing discrimination.
The case underscores how records of performance concerns may help employers defend against discrimination claims. However, employment attorneys have cautioned that documentation should avoid coded language and absolute statements, and should clearly set out expectations for employees.
Sources: HR Dive.