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A Couple Discriminatory Statements By Female VP Allow a Sex Discrimination Claim to Proceed


Lenart v. Coach, Inc. - United States District Court, Southern District of New York


Facts:  Todd Lenart ("Lenart") was hired by Coach in February 2012, by the Tax Department's Vice President Thomas Shortway.  In his position, Lenart served as Divisional Vice President of International Tax.  During his time at Coach, Lenart claimed that he experienced a hostile work environment and was discriminated against based upon his sex and gender by two female supervisors.  Lenart believed that men were subjected to a more rigorous hiring process than women and thought that Coach favored hiring women over men.  Even once an employee started at Coach, Lenart believed that women were given preferential treatment over men.  At one point, a male colleague of Lenart's said that a senior Vice President (who was female) said she wanted to have a staff of all women.

After working at Coach for about a year, Lenart was fired on the grounds of a reorganization of the tax function which resulted in the elimination of his position.  Apparently, most of Lenart's responsibilities were taken over by a female.  As well, a former colleague of Lenart told him that a senior Vice President (who was female) said during a meeting that she had created a "girl power team based in New York."

Lenart subsequently sued Coach on the grounds of sex discrimination, a violation of Title VII and a few New York statutes.  Coach moved to dismiss the complaint. 

Holding:  (For the purposes of this analysis, I am highlighting the portion of Lenart's claim that dealt with sex discrimination.).  The Court pointed out that in order for Lenart to defeat the motion to dismiss, he needed to have alleged that he "is a member of a protected class, was qualified, suffered an adverse employment action, and has at least minimal support for the proposition that the employer was motivated by discriminatory intent."  The fact that Lenart was replaced by a female (or his responsibilities were assumed by a female) was sufficient to establish at least an inference of discrimination.  

As well, an inference could be drawn that the female senior Vice President who made comments about a "girl power" team and that she wanted to have a staff of all women played a role in the decision to terminate Lenart.  As a result of these discriminatory statements and that a female assumed Lenart's responsibilities upon his termination, there was sufficient evidence to allow the claim to proceed.

Judgment:  The District Court found sufficient evidence to establish a discriminatory intent by Coach when it terminated Lenart to allow Lenart's sex discrimination claim proceed.

The Takeaway:  This case is an example of a claimant needing the bare minimum of evidence to not have their claim dismissed at the outset.  In this instance, the Court found just that:  the statements made by the senior Vice President lent themselves to the inference that women were favored over men.  Couple those statements with the fact that a female assumed most of Lenart's responsibilities when he was terminated, and given the low threshold to allow a claimant to proceed, Lenart's claim was not dismissed.  Whether this evidence of allegedly discriminatory statements has enough meat to get the case to trial is unclear.  But as with any good case, it lives to see another day. 

Majority Opinion Judge:  Judge Furman

Date:  September 11, 2015

Opinion:  hr.cch.com/ELD/LenartCoach.pdf

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