Introduction

The Sinnott v. Ridgewood Savings Bank case provides a revealing look into the mechanisms of workplace discrimination, particularly gender discrimination, and how such practices can permeate even institutions that claim to champion fairness. Kimberly Sinnott’s 21-year tenure at Ridgewood Savings Bank showcases the complexities of climbing the corporate ladder as a woman in a male-dominated environment, where promises of promotion can be derailed by bias and systemic gender-based discrimination.

In this legal commentary, we will examine Sinnott’s allegations involving violations of Title VII of the Civil Rights Act of 1964, the New York State Human Rights Law (NYSHRL), and the New York City Human Rights Law (NYCHRL). Additionally, this analysis will explore the broader implications of the Supreme Court’s decision in Muldrow v. City of St. Louis, which redefined what constitutes an adverse employment action under Title VII. The Muldrow decision has crucial implications for Sinnott’s case and others, particularly where the adverse action does not immediately involve a reduction in pay or an outright demotion but rather a more subtle undermining of career advancement and workplace equality.

In addition, we will analyze what legal claims could have been brought but were not and provide practical steps for employees who may find themselves in similar circumstances of discrimination, retaliation, and hostile work environments. This comprehensive discussion will help shed light on how discrimination manifests in corporate settings and the legal tools available to combat it.

1. Background: Sinnott’s Career and the Rise of Gender Discrimination

Kimberly Sinnott began her career at Ridgewood Savings Bank in 2001, initially hired as a Teller. Over the next 21 years, she received consistent promotions, increased responsibilities, and praise from senior management. She steadily rose to the position of Assistant Corporate Secretary by 2020, a role that placed her on the path to assuming the full responsibilities of Corporate Secretary when her superior, Laura Camelo, retired.

Throughout her career, Sinnott was recognized for her dedication and exceptional performance, receiving merit-based salary increases and bonuses. Her qualifications and experience made her the ideal candidate for the Corporate Secretary position, a fact acknowledged in the Bank’s succession planning documents. Sinnott had effectively been groomed for this leadership role, taking on many of the Corporate Secretary’s duties during Camelo’s gradual departure.

However, in 2017, the leadership landscape at Ridgewood Savings Bank shifted dramatically when Leonard Stekol was appointed as the new Chairman, President, and CEO. According to Sinnott, Stekol exhibited a clear bias against women in leadership positions. She alleges that he repeatedly questioned her about her personal life in ways that suggested a deep-seated bias, particularly concerning her marital status and lack of children. These inappropriate comments were never directed at male employees, highlighting a pattern of gender-based bias in his leadership approach.

Sinnott’s exclusion from key leadership roles culminated in 2021 when she was passed over for the Corporate Secretary position in favor of James Jewett, a male colleague with no experience with the duties required. This decision came despite years of promises from Bank leadership that Sinnott would be promoted when Camelo retired. After being passed over for the promotion, Sinnott faced escalating marginalization at work: she was excluded from key meetings, subjected to biased performance evaluations, and denied compensation for her additional duties as Assistant Corporate Secretary.

By September 2022, Sinnott could no longer tolerate the discriminatory treatment and hostile work environment at Ridgewood Savings Bank. She resigned after more than two decades of service, citing the hostile work environment and discriminatory practices as her reasons for leaving. Her lawsuit, filed in the United States District Court for the Eastern District of New York, seeks to hold Ridgewood Savings Bank accountable for violations of Title VII, the NYSHRL, and the NYCHRL.

2. Legal Framework: Title VII, NYSHRL, and NYCHRL Pre-Muldrow

Before the landmark decision in Muldrow v. City of St. Louis, employment discrimination claims under Title VII, the NYSHRL, and the NYCHRL required plaintiffs to show that they had suffered an adverse employment action. Courts traditionally interpreted “adverse employment actions” to include tangible outcomes, such as a demotion, reduction in pay, or termination. However, as the Muldrow case illustrates, subtle and often intangible actions, such as lateral transfers or exclusion from key responsibilities, can also amount to discrimination.

A. Title VII of the Civil Rights Act of 1964

Title VII is a cornerstone of federal civil rights law, prohibiting employment discrimination based on sex, race, color, religion, or national origin. To succeed on a Title VII claim, the plaintiff must establish that:

1. They are a member of a protected class.
2. They were qualified for the position they held or sought.
3. They experienced an adverse employment action.
4. The adverse action occurred under circumstances that give rise to an inference of discrimination.

In Sinnott v. Ridgewood Savings Bank, Sinnott is a member of a protected class as a woman, and she was qualified for the Corporate Secretary position, given her experience and prior succession planning that explicitly named her as the successor. The adverse employment actions she experienced include:

• Denial of promotion: Despite her qualifications, the Bank appointed a less-qualified male colleague to the position she had been groomed for over several years.
• Biased performance evaluations: After being passed over for promotion, Sinnott’s performance evaluations deteriorated despite her consistently excellent performance record.
• Exclusion from key responsibilities and meetings: Sinnott was systematically excluded from decision-making processes and denied access to crucial meetings that were crucial for her professional development and job performance.

These adverse actions occurred in a context that strongly suggests gender discrimination, especially in light of Stekol’s history of making inappropriate comments about Sinnott’s personal life and showing preferential treatment toward male employees.

B. New York State Human Rights Law (NYSHRL)

The NYSHRL mirrors many of the protections under Title VII and includes additional employee safeguards. Specifically, it prohibits discrimination based on marital status, gender identity, and sexual orientation, and it holds individuals personally accountable for participating in discriminatory practices.

Sinnott’s case under the NYSHRL is strengthened by the fact that Stekol’s inquiries into her personal life were not limited to gender-based comments but also focused on her marital status. By repeatedly questioning Sinnott about her single status and her decision not to have children, Stekol engaged in discriminatory behavior that falls within the NYSHRL’s prohibition on marital status discrimination.

Additionally, Sinnott experienced retaliation after raising concerns about being passed over for the Corporate Secretary role. The retaliation, which included biased performance evaluations and a reduction in her bonuses, provides further evidence of the hostile work environment she faced.

C. New York City Human Rights Law (NYCHRL)

The NYCHRL provides even broader protections than either Title VII or the NYSHRL, making it one of the most expansive anti-discrimination statutes in the United States. Under the NYCHRL, plaintiffs need only demonstrate that they were treated “less well” than other employees because of their protected characteristics rather than proving that they suffered a “materially adverse” employment action.

In Sinnott’s case, the NYCHRL framework works particularly well. She was treated less favorably than her male colleagues, excluded from meetings, denied a qualified promotion, and subjected to a hostile work environment. Under the NYCHRL, these actions need not be tied to a direct financial loss to be considered discriminatory. Instead, the law acknowledges that subtle forms of discrimination—such as exclusion from key responsibilities and biased evaluations—can be just as damaging to an employee’s career and mental well-being as more tangible forms like pay cuts or termination.

3. The Muldrow Decision: Redefining Adverse Employment Actions

The U.S. Supreme Court’s ruling in Muldrow v. City of St. Louis marked a significant shift in how courts assess employment discrimination claims, particularly about what constitutes an adverse employment action. Before Muldrow, plaintiffs generally needed to show that they had experienced a tangible adverse action, such as a demotion or a pay cut, to prevail in a Title VII claim. However, the Court’s decision in Muldrow expanded the definition of adverse employment actions to include non-tangible changes in working conditions, such as lateral transfers, significant changes in job responsibilities, or the denial of career advancement opportunities.

The Muldrow case involved a police officer who was transferred to a different unit without a change in pay or rank. Still, it argued that the transfer resulted in less favorable working conditions and fewer opportunities for advancement. The lower courts dismissed her claim, ruling that she had not suffered an adverse employment action because there was no material change in her compensation or job title. The Supreme Court disagreed, holding that an adverse action can include changes to an employee’s job responsibilities or working conditions that significantly affect their career trajectory or professional development, even if there is no immediate financial impact.

This broader interpretation of adverse employment actions provides greater protections for employees who experience subtler forms of discrimination that the courts might have otherwise dismissed. Under the Muldrow framework, actions like being excluded from key meetings, being passed over for promotion, or having one’s job responsibilities altered without corresponding recognition can now be considered discriminatory, even if they do not result in an immediate pay cut or demotion.

A. Redefining Adverse Employment Actions

The Muldrow decision expanded the scope of what qualifies as an adverse employment action under Title VII. No longer limited to tangible outcomes like demotions or pay cuts, adverse actions now include any significant changes to an employee’s job responsibilities, career prospects, or working conditions that result from discriminatory practices.

This redefinition is particularly relevant for employees like Sinnott, whose claims center on being marginalized and excluded from key responsibilities despite her qualifications. Before Muldrow, such actions might not have been considered “adverse” because they did not involve an immediate financial impact. However, under the expanded framework, the failure to promote Sinnott, combined with the exclusionary treatment she experienced, would likely be considered adverse actions, even though they did not involve an immediate pay cut.

B. How Muldrow Applies to Sinnott’s Case

The principles established in Muldrow can be directly applied to Sinnott’s case, strengthening her claims under Title VII and providing a more robust legal framework for proving that the actions taken against her were discriminatory. Several key aspects of Sinnott’s case align with the Muldrow standard for adverse employment actions:

1. Denial of Promotion: despite her qualifications and succession planning documents, Sinnott’s promotion to Corporate Secretary is a classic example of an adverse action under Muldrow. Even though Sinnott did not experience a pay cut or demotion, denying the promotion significantly altered her career trajectory. It prevented her from advancing to the leadership role she had been groomed for. The failure to promote her and appoint a less-qualified male colleague would likely be considered an adverse action under the new Muldrow standard.
2. Exclusion from Key Meetings: Sinnott’s exclusion from important meetings and decision-making processes further fits within the expanded definition of adverse actions. The exclusion hindered her ability to perform her job effectively and undermined her professional standing within the organization. Under the Muldrow framework, these exclusions can be considered adverse actions, even if they did not immediately affect her paycheck.
3. Hostile Work Environment: Sinnott’s work environment became increasingly hostile after she was passed over for promotion. The exclusionary behavior, biased performance evaluations, and reduced bonuses all contributed to a work environment where she felt marginalized and unsupported. Under the Muldrow standard, these actions would likely qualify as adverse employment actions because they significantly altered the conditions of her employment and contributed to her eventual resignation.
4. Biased Performance Evaluations: After being passed over for promotion, Sinnott’s performance evaluations were downgraded despite her strong track record of excellent performance. These biased evaluations affected her compensation and damaged her reputation within the organization. Under Muldrow, biased performance evaluations can be considered adverse actions, particularly if they were motivated by discriminatory intent.

4. Potential Legal Claims Not Pursued in Sinnott’s Case

While Sinnott’s complaint covers a broad range of legal claims under Title VII, the NYSHRL, and the NYCHRL, she might have pursued several additional legal claims to strengthen her case further. These include potential Equal Pay Act (EPA) violations, a breach of contract claim based on the Bank’s assurances that she would be promoted, and a constructive discharge claim.

A. Equal Pay Act (EPA) Violation

The Equal Pay Act (EPA) requires that men and women be paid equally for similar work. Under the EPA, wage discrimination based on gender is prohibited, and employers must provide equal pay for equal work, regardless of the employee’s gender.

Sinnott’s case has a clear potential for an EPA claim. After Camelo’s retirement, Sinnott took on many of the duties of the Corporate Secretary role. Still, she was not compensated at the same level as James Jewett, who held the formal title. Jewett, who had no experience with the Corporate Secretary’s responsibilities, was paid more than Sinnott despite performing fewer duties. This wage disparity and Sinnott’s assumption of substantially similar (if not greater) responsibilities provide a strong basis for an EPA claim.

To succeed on an EPA claim, Sinnott would need to demonstrate that:

1. She and Jewett performed substantially equal work.
2. They worked under similar conditions.
3. Jewett was paid more than Sinnott for performing the same or similar work.

Since Sinnott took on most of the Corporate Secretary’s responsibilities while Jewett received the title and higher pay, this claim could have significantly bolstered her case.

B. Breach of Contract

Sinnott could also have pursued a breach of contract claim based on the Bank’s assurances that she would be promoted to Corporate Secretary. The Bank’s succession planning documents explicitly named Sinnott as the designated successor, and she was repeatedly assured that she would receive the promotion if she continued to perform well.

While New York is an at-will employment state, employers can terminate employees for any reason (or no reason). A breach of contract claim can still succeed if the plaintiff can demonstrate that the employer made a clear and specific promise. In Sinnott’s case, the Bank’s detailed succession planning documents and repeated verbal assurances regarding her promotion could form the basis of a contractual obligation that the Bank failed to fulfill.

C. Constructive Discharge

Although Sinnott resigned from her position in September 2022, she could argue that she was constructively discharged. A constructive discharge occurs when an employer creates such intolerable working conditions that a reasonable person in the employee’s position would feel compelled to resign. In Sinnott’s case, the ongoing discrimination, exclusion from meetings, and biased performance evaluations created a hostile work environment that ultimately forced her to resign.

Constructive discharge claims are often pursued with hostile work environment claims, as they can significantly increase the potential damages awarded. If Sinnott could prove that the Bank’s discriminatory actions directly caused her resignation, she may be entitled to additional compensation for lost wages and emotional distress.

5. Practical Steps for Employees Facing Similar Legal Issues: Reporting and Filing Discrimination Claims

For employees in situations similar to Sinnott’s—facing discrimination, retaliation, or a hostile work environment—it is crucial to take proactive steps to protect their rights and build a strong legal case. Beyond documenting discriminatory actions and seeking legal counsel, it’s important to understand where and how to report these issues and the relevant timeframes under federal, state, and local laws.

Below are key steps and detailed guidelines on reporting employment discrimination under Title VII, the New York State Human Rights Law (NYSHRL), and the New York City Human Rights Law (NYCHRL). This section also provides insight into the statutes of limitations and reporting deadlines that apply to such cases.

A. Reporting Discrimination Under Title VII of the Civil Rights Act of 1964

Title VII is a federal law prohibiting employment discrimination based on sex, race, color, national origin, and religion. Employees who believe they have experienced discrimination under Title VII must follow specific procedures to file a complaint and seek legal redress.

i. Reporting Authority: The Equal Employment Opportunity Commission (EEOC)

To report discrimination under Title VII, employees must file a charge of discrimination with the United States Equal Employment Opportunity Commission (EEOC), the federal agency responsible for enforcing federal anti-discrimination laws in the workplace. The EEOC investigates allegations of workplace discrimination and has the authority to bring lawsuits against employers for violations of Title VII.

ii. Timeframe for Filing: 180 or 300 Days

The deadline for filing a charge of discrimination with the EEOC varies based on the location of the incident and whether a state or local anti-discrimination law is also in place:

• 180-Day Deadline: In states or jurisdictions that do not have their own anti-discrimination laws or agencies, the deadline for filing a charge with the EEOC is 180 days from the date of the alleged discriminatory act.
• 300-Day Deadline: In states with their own anti-discrimination laws (such as New York) and agencies that enforce those laws, the deadline for filing a charge with the EEOC is extended to 300 days from the date of the alleged discriminatory act. Because New York has the NYSHRL and NYCHRL, employees in New York benefit from the 300-day filing deadline.

iii. Process of Filing a Complaint

To file a complaint with the EEOC, employees must take the following steps:

1. Prepare the Charge: Gather detailed information about the discriminatory incident(s), including dates, names of those involved, and specific actions demonstrating discrimination.
2. File the Charge: A charge of discrimination can be filed online, in person at an EEOC office, or by mail. Employees can choose to file on their own or with the assistance of an attorney.
3. Investigation: Once the charge is filed, the EEOC will investigate the allegations by reviewing evidence, interviewing witnesses, and possibly conducting mediation between the employee and employer.
4. Notice of Right to Sue: If the EEOC does not resolve the issue within 180 days or concludes its investigation, it may issue a Notice of Right to Sue, allowing the employee to file a lawsuit in federal court within 90 days of receiving the notice.

iv. Retaliation Protections

Title VII also protects employees from retaliation if they file a complaint or participate in an investigation. Retaliatory actions, such as demotion, harassment, or termination, can form the basis of a separate discrimination or retaliation claim.

B. Reporting Discrimination Under the New York State Human Rights Law (NYSHRL)

The NYSHRL provides additional protections to employees in New York, prohibiting discrimination based on gender, race, sexual orientation, marital status, age, disability, and more. Employees can file discrimination claims under the NYSHRL through the New York State Division of Human Rights (NYSDHR), the agency responsible for enforcing state anti-discrimination laws.

i. Reporting Authority: New York State Division of Human Rights (NYSDHR)

The New York State Division of Human Rights (NYSDHR) is tasked with investigating and addressing workplace discrimination claims under the NYSHRL. Employees can file complaints directly with the NYSDHR, and the agency will investigate whether discrimination occurred.

ii. Timeframe for Filing: One Year or Three Years

The statute of limitations for filing a claim of discrimination under the NYSHRL depends on the nature of the complaint:

• One Year: Employees must file a claim with the NYSDHR within one year of the discriminatory incident.
• Three Years: If the employee opts to file a lawsuit in state court instead of with the NYSDHR, they have three years from the date of the discriminatory act to file.

iii. Filing Process with the NYSDHR

1. File a Complaint: Employees can file a complaint with the NYSDHR online, by mail, or in person. The complaint should include a detailed account of the discrimination, supporting evidence, and any communications with the employer regarding the issue.
2. Investigation: The NYSDHR will open an investigation and gather evidence from the employee and the employer. The investigation may involve interviews, document reviews, and site visits.
3. Administrative Hearing: If the NYSDHR finds probable cause to believe discrimination occurred, it will schedule an administrative hearing where both sides can present their cases.
4. Remedies: If the NYSDHR determines that discrimination occurred, it can order remedies such as back pay, reinstatement, compensation for emotional distress, and civil fines.

iv. Relationship Between the NYSDHR and EEOC

Employees can file discrimination claims under both the NYSHRL and Title VII through a process called dual filing. This allows employees to file a single complaint investigated by the NYSDHR and the EEOC, ensuring that they benefit from federal and state protections.

C. Reporting Discrimination Under the New York City Human Rights Law (NYCHRL)

The NYCHRL offers some of the most comprehensive employment protections in the United States, particularly for employees in New York City. It prohibits discrimination based on gender, race, national origin, sexual orientation, marital status, etc. Employees who believe they have experienced discrimination under the NYCHRL can file a complaint with the New York City Commission on Human Rights (NYCCHR).

i. Reporting Authority: New York City Commission on Human Rights (NYCCHR)

The New York City Commission on Human Rights (NYCCHR) enforces the NYCHRL. Employees can file complaints with the NYCCHR if they believe they have been discriminated against based on any of the protected characteristics covered by the NYCHRL.

ii. Timeframe for Filing: One Year or Three Years

• One Year: Employees must file a complaint with the NYCCHR within one year of the discriminatory incident.
• Three Years: If the employee prefers to file a lawsuit directly in state court, they have three years from the date of the discriminatory act to do so.

iii. Filing Process with the NYCCHR

1. File a Complaint: Employees can file a complaint online, by mail, or in person at the NYCCHR’s office. The complaint should describe the discriminatory actions, the individuals involved, and any supporting evidence.
2. Investigation: The NYCCHR will investigate the complaint by gathering evidence, interviewing witnesses, and reviewing documents. The agency may also attempt mediation between the employee and employer to resolve the dispute.
3. Hearing and Remedies: If the investigation finds probable cause for discrimination, the case will be heard before an administrative law judge. Remedies may include back pay, reinstatement, emotional distress damages, and civil penalties against the employer.

iv. Dual Filing with the NYSDHR and EEOC

Similar to claims under the NYSHRL, employees can dual-file discrimination complaints under the NYCHRL and Title VII. This ensures that the complaint is reviewed under federal and local laws, giving the employee access to a broader range of legal remedies.

D. Statutes of Limitations: Summary of Deadlines

Here is a quick overview of the deadlines for filing discrimination claims under Title VII, NYSHRL, and NYCHRL:

• Title VII:
  • 180 days to file with the EEOC (if no state law applies).
  • 300 days to file with the EEOC (if a state or local law applies, as in New York).
• NYSHRL:
  • One year to file a complaint with the NYSDHR.
  • Three years to file a lawsuit in state court.
• NYCHRL:
  • One year to file a complaint with the NYCCHR.
  • Three years to file a lawsuit in state court.

It is important to consult with an attorney as soon as possible after experiencing discrimination to ensure that you meet these filing deadlines and preserve your right to seek legal remedies.

Conclusion

If you believe you have been subjected to discrimination, retaliation, or a hostile work environment, it is critical to take immediate action to protect your rights. Filing complaints with the appropriate agencies under Title VII, NYSHRL, and NYCHRL can provide access to legal remedies, including compensation for lost wages, emotional distress, and punitive damages.

Understanding the reporting requirements and timeframes is essential for properly reviewing your case. Filing within the designated deadlines, documenting incidents of discrimination, and consulting with an experienced employment lawyer are key steps to building a strong case and securing the justice you deserve.

If you or someone you know is facing workplace discrimination, harassment, or retaliation, it is crucial to take action. Contact legal professionals specializing in labor and employment law to explore your options. Stay informed about your rights and the legal protections available to you. Follow us on LinkedIn, Facebook, and YouTube for updates on employment law and other legal matters. Visit our website at The Sanders Firm, P.C., for more information and to sign up for our newsletter. Together, we can work towards creating safer and more equitable workplaces for everyone.

Read the Federal Complaint