Benson v. North Shore-Long Island Jewish Health Systems
Plaintiff Selina Benson filed a complaint against North Shore-Long Island Jewish Health Systems and individual defendants, alleging discrimination based on race, gender, disability, sexual orientation, and marital status, along with retaliation and breach of implied contract, under Title VII, NYSHRL, and 42 U.S.C. §§ 1981, 1985, and 1986. The defendants filed a motion to dismiss various claims. The court dismissed most NYSHRL claims (except retaliatory discharge) due to the election of remedies doctrine, and similarly dismissed most §§ 1981, 1985, and 1986 claims against North Shore due to preclusion. Additionally, Title VII claims against individual defendants and those alleging sexual orientation discrimination were dismissed. However, the court denied the motion to dismiss claims as time-barred under the continuing violation doctrine and dismissed the implied breach of contract claim, while allowing the plaintiff to amend the complaint to add a collective bargaining agreement claim.