Spencer v. International Shoppes, Inc.
Plaintiff Arleigh Spencer initiated an action against International Shoppes, Inc. and Michael Halpern, alleging race and age-based discrimination and retaliation. While many discrimination claims were dismissed, claims of retaliatory commencement of litigation under Title VII, NYHRL, and § 1981 remained. Defendants moved for a second summary judgment, contending that their partially successful state court defamation lawsuit against Spencer precluded a finding of retaliatory intent. The Court denied the motion, ruling that the 'well-founded lawsuit' standard from NLRA cases was not applicable to employment discrimination retaliation claims and that, even if it were, Defendants' success on only one of eight claims did not negate the possibility of retaliatory motive, particularly given the timing and high damages sought in the initial state court action.