Curtis v. Radioshack Corp.
Plaintiff Jennifer Curtis filed a discrimination charge against RadioShack Corporation alleging pregnancy-based sex discrimination and retaliatory discharge under Title VII. Her charge was filed 342 days after her termination, exceeding the 300-day statutory limit. Curtis sought equitable tolling, arguing that the Dutchess County Human Rights Commission (DCHCR) misled her and lost her file. However, the court found that DCHCR explicitly stated it did not investigate complaints and that Curtis lacked reasonable diligence in following up for over seven months. Consequently, the court denied equitable tolling and granted RadioShack's motion to dismiss Curtis's First, Second, and Third causes of action as time-barred. Surviving claims exist under New York State Human Rights Law, Fair Labor Standards Act, and New York State Labor Law.