Muhammad v. New York City Transit Authority
Plaintiff, an African-American Muslim bus driver, brought an employment discrimination lawsuit against the New York City Transit Authority (NYCTA), alleging gender, religious, and racial discrimination due to her employer's policies regarding religious headwear. NYCTA moved to dismiss four of her eleven causes of action. The court granted dismissal of the Title VII hostile work environment claim, finding co-worker hostility stemmed from jealousy over work assignments, not protected characteristics. The Title VII race discrimination claim was also dismissed as it was not reasonably related to the plaintiff's initial EEOC charge. However, the court denied dismissal of the claim under New York City Administrative Law § 8-107(1), rejecting NYCTA's argument of statutory exemption. Lastly, the religious discrimination claim under the New York State Constitution Article I, § 3 was dismissed because other statutory remedies, like the New York Human Rights Law, were available to the plaintiff.