Nolley v. Swiss Reinsurance America Corp.
Plaintiff James Nolley sued Swiss Re America Holding Corporation for employment discrimination based on race and retaliation under Title VII, NYSHRL, and NYCHRL. Nolley alleged discrimination regarding promotion, exclusion from meetings, assignment of lesser work, issuance of a Performance Improvement Plan (PIP), and termination of employment. The court dismissed the Title VII claims as untimely. For the remaining discrimination claims, the court found Swiss Re provided legitimate, nondiscriminatory reasons for its actions, citing concerns over Nolley's aggressive demeanor and poor performance. Nolley failed to demonstrate these reasons were pretextual or that discrimination was a motivating factor. The court also granted summary judgment to Swiss Re on Nolley's retaliation claim, finding no direct evidence of retaliatory motive and that intervening events defeated the inference of causation.