Bernstein v. Seeman
Pro se plaintiff Jeffery Bernstein brought an action against May Seeman, MEAG NY Corporation, Munich Reinsurance America, Inc., and Munich Reinsurance Germany, alleging religious discrimination and retaliation under Title VII of the Civil Rights Act of 1964, and defamation. Defendants moved to dismiss the amended complaint. The court granted the motion to dismiss against Seeman entirely and the defamation claim against MEAG NY, citing no individual liability under Title VII and absolute immunity for the alleged defamatory statements. However, the court denied Munich Re's motion to dismiss the Title VII claim, finding plausible employer liability and an "identity of interest" exception for not being named in the EEOC charge, while granting dismissal for the defamation claim against Munich Re on the basis of absolute privilege.