Second Circuit Reinstates Race Discrimination Case

On October 23, 2025, the U.S. Court of Appeals for the Second Circuit in Brown v. Montefiore Health System found that a former Montefiore employee has sufficiently alleged race discrimination and hostile work environment claims, overturning a trial court ruling that had dismissed the case.

The plaintiff, Brown, is a Black dietician who worked at Montefiore for over twenty years. She claims that her supervisor systematically excluded and mistreated Black employees, as evidenced by the fact that she was the only Black employee in her department; her supervisor hired nearly all white employees, rejecting a qualified Black applicant after meeting her in person; other Black employees also complained about discrimination by the same supervisor; and her supervisor denied her opportunities, accommodations, and fair treatment to try and push her out of her job.

While no racial slurs were alleged, the Court found that these facts, taken together, suggest a pattern of racial bias and are enough to plausibly infer discrimination. In reaching their holding, the Court of Appeals reaffirmed that New York State Human Rights Law claims are analyzed under the more plaintiff-friendly New York City Human Rights Law standards, despite not explicitly citing cases to support this proposition. Further, the Court looked to company-wide practices and treatment of other employees, as well as small acts of unfair treatment, viewed as a whole, to create and support a picture of discrimination.

Brown was issued as a summary order, meaning it has limited precedential effect, but the principles used by the Court in coming to their decision are taken from precedential rulings. The case will now proceed to discovery. This case is significant in that even absent racial epithets or other race-specific allegations, the Court looked at a totality of the circumstances to find that a series of events, in their totality, altered the work environment to create an inference of race discrimination.