Spadola v. New York City Transit Authority
Plaintiff Terry Spadola, a Line Supervisor for the New York City Transit Authority, brought an action under Title VII of the Civil Rights Act of 1964, alleging unlawful retaliation. He claimed that successive disciplinary proceedings, which ultimately led to his dismissal, were in response to his objection to a supervisor's comment he regarded as sexual harassment. The defendants, New York City Transit Authority and Manhattan and Bronx Surface Transit Operating Authority, moved for summary judgment. The court granted the motion, concluding that Spadola failed to establish a prima facie case of unlawful retaliation under Title VII, as his belief of sexual harassment was not objectively reasonable and there was insufficient evidence of a causal connection between his protected activity and adverse employment actions.