Summary
The United States Court of Appeals for the Second Circuit affirmed summary judgment for the New York City Police Department and Commissioner Raymond Kelly in Crystal D. Lewis’s employment discrimination and retaliation claims. The claims arose under Title VII, the Age Discrimination in Employment Act, the Americans with Disabilities Act, and the Family and Medical Leave Act.
Topics
Practice areas
Questions Presented
- Whether the district court properly granted summary judgment to defendants on Lewis's employment discrimination claims under Title VII and the Age Discrimination in Employment Act.
- Whether the district court properly granted summary judgment on Lewis's discrimination and retaliation claims under the Americans with Disabilities Act and the Family and Medical Leave Act.
Holdings
- The district court properly granted summary judgment to defendants, and the judgment was affirmed.
Key quotations
“We review a district court’s grant of summary judgment de novo, construing the evidence in the light most favorable to the non-moving party and drawing all reasonable inferences in its favor.” (537 F. App'x at 12)
“We will affirm the judgment only if there is no genuine issue as to any material fact, and if the moving party is entitled to a judgment as a matter of law.” (537 F. App'x at 12)
“Where the record taken as a whole could not lead a rational trier of fact to find for the non-moving party.” (537 F. App'x at 12)
Factual background
Lewis asserted claims against the New York City Police Department and Commissioner Raymond Kelly for discrimination under Title VII and the Age Discrimination in Employment Act, and discrimination and retaliation under the Americans with Disabilities Act and the Family and Medical Leave Act. The opinion does not recount the underlying factual record in detail, instead relying on the district court's thorough decision and an independent review of the record and relevant law.
Procedural history
The district court granted summary judgment in favor of the New York City Police Department and Commissioner Raymond Kelly. Lewis appealed, and the Second Circuit affirmed by summary order for substantially the same reasons stated in the district court's November 8, 2012 decision.