Shapiro v. State of New York
Leonard R. Shapiro, an Administrative Law Judge, appealed an order granting summary judgment to the State of New York and individual defendants in an action alleging age discrimination and retaliation under the New York State Human Rights Law and 42 USC § 1983. Shapiro claimed he faced adverse employment actions, including excessive workload, temporary removal of supervisory duties, and not being considered for a senior position. The Supreme Court dismissed the complaint. The Appellate Division, Second Department, affirmed, finding that the defendants established, prima facie, that Shapiro did not suffer a materially adverse employment action for his discrimination claims, and for his retaliation claims, there was no causal connection between any protected activity and the alleged adverse actions. Consequently, the claims for aiding and abetting discrimination also failed.