Seale v. Madison Cnty
Plaintiffs Kelly Seale and David Seale filed an employment discrimination action against Madison County and five individual defendants, alleging violations under Title VII, NYHRL, and 42 U.S.C. §§ 1983, 1985. Defendants moved for judgment on the pleadings and to dismiss for lack of subject matter jurisdiction. The Court dismissed David Seale's Title VII claims for lack of subject matter jurisdiction and granted dismissal for most other claims not specifically outlined. However, Kelly Seale's hostile work environment claims (under Title VII, NYHRL against the County, and § 1983 against Episcopo), her retaliation claims (under Title VII against the County, and NYHRL against County, Riley, Episcopo, Aylward), and her First Amendment retaliation claims (against County, Riley, Episcopo, Aylward) survived. David Seale's First Amendment retaliation claim also survived against County, Riley, Bailey, Episcopo, and Aylward. Defendant Cary was terminated as a party.