Kleehammer v. Monroe County
This case involves an employment sex discrimination and retaliation lawsuit filed by Plaintiff Kleehammer against Monroe County and Sheriff O'Flynn. Kleehammer alleges hostile work environment and retaliation under Title VII, NYSHRL, and 42 U.S.C. § 1983. The hostile environment claim stemmed from a single incident involving a female visitor and a male inmate, and subsequent lewd comments by co-workers. Kleehammer also claimed retaliation for complaining about the hostile environment and for alleged denial of "Z time" leave. The Court granted in part and denied in part the defendants' motion for judgment on the pleadings, dismissing the hostile environment and Equal Protection/Fourth Amendment claims due to insufficient pleading and lack of employer liability for co-worker conduct, but allowed the retaliation claims (Third and Fourth causes of action) to proceed. The Court cautioned Plaintiff's counsel regarding Federal Rule of Civil Procedure 11 for good faith pleading.