Serrano v. 900 5th Avenue Corp.
Defendants Brown Harris Stevens Residential Management (BHS) and 900 5th Avenue Corp. (900 5th) moved to dismiss an employment discrimination case, citing lack of subject matter jurisdiction. BHS argued it was not the plaintiff's employer, while 900 5th contended it did not meet Title VII's 15-employee minimum for an employer. The court denied BHS's motion, determining that BHS significantly affected the employment opportunities at 900 5th through its contractual authority and actions related to hiring, firing, discipline, and labor relations, thus falling within the broad definition of an "employer" under Title VII. Conversely, the court granted 900 5th's motion, ruling that its employees could not be counted with BHS's under a "joint employer" theory to satisfy the 15-employee minimum, as such an interpretation would contradict the purpose of protecting small businesses from Title VII liability.