Mi-Kyung Cho v. Young Bin Café
The plaintiff, Mi-Kyung Cho, a hostess at Young Bin Café in Flushing, New York, sued her employers, Young Bin Café and Gabin, following a physical assault by a customer in 2008. She alleged negligence, retaliatory discharge under New York and New Jersey anti-discrimination laws, intentional infliction of emotional distress, and tortious interference with business relations and contract. The court granted summary judgment to the defendants, dismissing all claims. It found that her complaints (a police report and a request for workers' compensation) were not 'protected activity' under the relevant human rights laws, her tortious interference claims lacked merit due to a lack of identified relationships/contracts, and her intentional infliction of emotional distress claim was time-barred by New York's one-year statute of limitations.