Grella v. St. Francis Hospital
Patricia Grella appealed a Supreme Court order that granted summary judgment dismissing her complaint against St. Francis Hospital and Heart Center Federal Credit Union. Grella alleged unlawful age discrimination under the Human Rights Law and retaliation under Labor Law § 215, stemming from her separation from employment in 2011. She contended she was discharged due to her age (50 and replaced by a 25-year-old) and in retaliation for complaining about an inconsistent vacation day policy. The Appellate Division, Second Department, affirmed the lower court's decision. While the court acknowledged triable issues of fact regarding Grella's prima facie age discrimination claim, it ultimately found that the defendants had presented legitimate, non-discriminatory reasons for her termination (aggressive behavior) and that Grella failed to demonstrate these reasons were a pretext for discrimination. Furthermore, her retaliation claim failed as she did not identify a specific provision of the Labor Law that she reasonably believed was violated.