Gray v. Shearson Lehman Bros., Inc.
Eddie Gray sued Shearson Lehman Brothers, Inc., and three individual defendants for employment discrimination under Title VII, New York Executive Law, and New York City Human Rights Law, along with unlawful termination under New York's whistleblower statute. Defendants moved to dismiss various claims. The court granted the defendants' motions, dismissing portions of the Title VII claims as time-barred, all Title VII claims against individual defendants, and the claims under the whistleblower statute and New York City Human Rights Law entirely. The court found that Gray's 1987 and 1989 Title VII claims were time-barred, not falling under the 'continuing violation' exception. It also ruled that individual defendants cannot be held personally liable under Title VII and dismissed those claims. Finally, Gray's whistleblower claim was dismissed as time-barred, and his New York City Human Rights Law claim was dismissed due to non-compliance with statutory prerequisites.