Margaret Doe, Appellant, v Bloomberg L.P. et al., Defendants, and Michael Bloomberg, Respondent., 36 N.Y.3d 450

Summary

HOLDINGS: [1]-The president of a company was not an "employer" within the meaning of the New York City Human Rights Law (HRL), Administrative Code of the City of NY § 8-107, and accordingly, the dismissal of an employee's claims that sought to hold him vicariously liable for a supervisor's offending conduct was affirmed; [2]-The employee failed to allege that the president was her employer for purposes of liability under the City HRL because her allegations concerning his position at the company demonstrated only that he was an owner or officer. The employee's allegations that the president fostered a culture of discrimination and sexual harassment at the company, based primarily on news articles and reports of a deposition in an unrelated case, did not transform him into an employer for purposes of vicarious liability for the supervisor's discriminatory conduct under § 8-107(13)(b).