Cortes v. City of New York
Plaintiff Frankie Cortes, a former Corrections Officer with the New York City Department of Correction, filed an action alleging retaliation and discrimination based on gender and race under Title VII, Sections 1981, 1983, 1985, and New York state and city human rights laws. Defendants moved to dismiss the complaint in its entirety. The Court dismissed Title VII claims against individual defendants and sex discrimination-based Section 1981 claims with prejudice. The Section 1985 conspiracy claim was dismissed with leave to replead. However, the Court denied the motion to dismiss retaliation and racial discrimination claims under Section 1981, as well as First Amendment retaliation and Equal Protection claims under Section 1983. Motions to dismiss based on statute of limitations and exhaustion of remedies for Title VII hostile work environment and SHRL/CHRL claims were also denied, without prejudice to renewal at a later stage.