Beattie v. Farnsworth Middle School
Plaintiff Patricia Beattie, a part-time paraprofessional, filed a sex discrimination action against the Guilderland Central School District and several individual defendants, alleging sexual harassment by Roger Levinthal and retaliation after she reported the harassment. The court addressed motions to dismiss, finding that the sexual harassment claims were largely time-barred under Title VII due to the continuing violation exception not applying, and employer liability for co-worker harassment was not established for the physical acts. However, the court denied the motion to dismiss Plaintiff's Title VII retaliation claim, finding sufficient facts to support a prima facie case. Individual defendants' motions to dismiss for individual liability under HRL and Section 1983 were granted, except for Roger Levinthal. The Section 1985 conspiracy claim was also dismissed for lack of specific discriminatory animus.