Nunez v. A-T Financial Information, Inc.
Plaintiff, an account executive at A-T Financial Information, Inc. (ATF), alleged sexual harassment and discrimination by defendant Andrews, ATF's Vice President of Sales. During a sales dinner, Andrews made crude sexual remarks to the plaintiff. Following the incident, plaintiff reported the conduct, experienced a deterioration in her work relationships, and was ultimately terminated by ATF. She filed a lawsuit alleging violations of federal and New York Human Rights Law, as well as common law claims for defamation, intentional infliction of emotional distress, and breach of an implied covenant of good faith and fair dealing. The court granted ATF's motion to dismiss the common law claims, ruling that the defamation claim lacked special damages, Andrews' conduct, while reprehensible, did not meet the 'outrageous' standard for emotional distress, and New York law does not recognize an implied covenant in at-will employment.