St. Vincent's Hospital & Medical Center v. Division of Human Rights of the Executive Department
Elizabeth Hart, former Director of Nutrition at St. Vincent’s Hospital, filed an age and sex discrimination complaint with the NY Division of Human Rights in 1981. Concurrently, she filed a state court action, later removed to federal court (82 Civ. 1478), asserting federal Age Discrimination in Employment Act and state Human Rights Law claims. The federal claims were voluntarily dismissed with prejudice. Plaintiffs (St. Vincent's Hospital and ARA Hospital Food Management) now seek a declaratory judgment, arguing that this dismissal bars the Division of Human Rights' continued investigation. This Court finds it has jurisdiction under the All Writs Statute but concludes that the voluntary dismissal with prejudice does not have res judicata or collateral estoppel effect on the state agency proceeding because the federal court never reached the merits due to a procedural bar under Section 300 of the NY Human Rights Law. The Court also declines to enjoin the state administrative proceeding based on Hart's alleged non-compliance with state procedural requirements, citing lack of federal jurisdiction and principles of comity. Consequently, the motion to dismiss the declaratory judgment complaint is granted, and Hart's request for attorney's fees is denied.