Suzan Russell v. New York University

Summary

The Court of Appeals affirmed dismissal of plaintiff’s State and City Human Rights Law claims because factual determinations made after full federal litigation barred relitigation under collateral estoppel. Those determinations established that NYU’s response was not negligent, plaintiff lacked evidence of discrimination or retaliation, and NYU’s stated reason for termination was not pretextual. The court also held that coworkers may be individually liable under the City Human Rights Law only when they have a role in administering the plaintiff’s compensation, terms, conditions, or privileges of employment.