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Flynn v. Bronx Parent Housing Network

City's Liability Under Title VII for BPHN's Actions Not Plausibly Alleged

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MEMORANDUM AND ORDER In 2021, counsel for plaintiff Qiana Flynn (“plaintiff” or “Flynn”) filed this case and three substantially similar cases in this District on behalf of former employees of Bronx Parent Housing Network (“BPHN”), who were allegedly terminated after complaining of sexual harassment and a hostile work environment at BPHN. See ECF No. 1¹; Byron v. Bronx Parent Hous. Network, No. 21 Civ. 2568 (MKV); Britton v. Bronx Parent Hous. Network, No. 21 Civ. 7079 (JPO); Taylor v. Bronx Parent Hous. Network, No. 21 Civ. 4890 (JLR). All four cases were brought against the same three defendants — BPHN; BPHN’s former director, Victor Rivera; and the City of New York (the “City”), see id. — and asserted the same five causes of action: (1) violations of Title VII of the Civil Rights Act of 1964 (“Title VII”); (2) violations of New York Labor Law §201-g; (3) violations of New York City Human Rights Law (“NYCHRL”) §8-107²; (4) assorted New York state common law claims for “assault, battery, negligence, prima facie tort, sexual assault, unlawful touching”; and (5) an unspecified claim that the City had knowledge of the alleged misconduct at BPHN and continued to provide funding to BPHN. See First Amended Complaint (“FAC”)

2-4, 72-77, ECF No. 32; Byron v. Bronx Parent Hous. Network, No. 21 Civ. 2568 (MKV), 2023 WL 2585824, at *1 (S.D.N.Y. Mar. 20, 2023); Britton v. Bronx Parent Hous. Network, No. 21 Civ. 7079 (JPO), 2022 WL 4332735, at *1 (S.D.N.Y. Sept. 19, 2022); Taylor, No. 21 Civ. 4890 (JLR), ECF No. 35

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