Bohlke v. General Electric Co.
Plaintiffs, former employees, initiated an age discrimination lawsuit against their former employer under the Human Rights Law, asserting claims based on both disparate treatment and disparate impact theories. The defendant contested the disparate impact claims, arguing they were not recognized under New York law. While the Supreme Court initially ruled in favor of the plaintiffs regarding discovery and amendment, the appellate court reversed this decision. The appellate court determined that disparate impact claims are not cognizable under the New York Human Rights Law for age discrimination when the protected class is defined as broadly as individuals aged 18 and over, making it impossible for a subgroup (e.g., over 40) to demonstrate disparate impact on the entire class. Consequently, the court dismissed the disparate impact claims and denied the plaintiffs' motion to amend their complaint. Additionally, the appellate court reversed a sua sponte discovery order by the Supreme Court, citing a lack of notice and opportunity for the defendant to be heard on those specific demands.