Matter of McCabe v. 511 W. 232nd Owners Corp.
Maryann McCabe, who lived with her long-term romantic partner David Burrows in his cooperative unit, sought to acquire his lease and shares after his death. The cooperative board denied her request for an automatic transfer, which was available to a shareholder's "spouse," because she was not legally married to Burrows. McCabe argued that this denial constituted marital status discrimination under the New York City Human Rights Law (NYCHRL). The Court of Appeals affirmed the lower court's decision, holding that "marital status" in the NYCHRL refers to the legal condition of being single, married, divorced, or widowed, and does not extend to discrimination based on one's relationship to a particular person (i.e., not being married to Burrows). The Court found that the City Council's legislative history and subsequent amendments, including the addition of "partnership status" and "caregiver status," indicated a deliberate scope of protections that did not encompass unmarried romantic partners for automatic transfer of shares based on "marital status."