Wednesday, January 1, 2014

Taylor v. Metzger case brief

Taylor v. Metzger case brief summary
706 A.2d 685 (1998)

CASE SYNOPSIS
Plaintiff sheriff's officer sought review of the judgment of the Superior Court, Appellate Division (New Jersey), which affirmed the lower court's order granting summary judgment in favor of defendant sheriff in plaintiff's action against defendant to recover damages resulting from defendant's violation of the Law Against Discrimination, N.J. Stat. Ann. §§ 10:5-1 to -42, intentional infliction of emotional distress, and prima facie tort.

CASE FACTS
Plaintiff sheriff's officer sued defendant sheriff to recover damages resulting from defendant's violation of the Law Against Discrimination (LAD), N.J. Stat. Ann. §§ 10:5-1 to -42, intentional infliction of emotional distress, and prima facie tort.

PROCEDURAL HISTORY
The trial court granted defendant's motion for summary judgment, and the intermediate appellate court affirmed that decision. Plaintiff petitioned the court for review.

DISCUSSION

  • On review, the court reversed in part, affirmed in part, and remanded the case for further proceedings. 
  • Regarding her racial discrimination claim based on workplace harassment, plaintiff presented sufficient evidence from which a rational factfinder could have found that defendant engaged in discriminatory harassment by uttering a racial epithet that was sufficiently severe to have created a hostile work environment. 
  • Defendant was not entitled to summary judgment on plaintiff's emotional distress claim due to the factual dispute regarding whether defendant's remark would have caused the average African-American to suffer sever emotional distress. 
  • Under the facts, the court refused to recognize plaintiff's prima facie tort claim, which the trial court properly dismissed.

CONCLUSION
The court reversed in part, affirmed in part, and remanded the case for trial. Plaintiff sheriff's officer presented sufficient evidence to survive defendant sheriff's motion for summary judgment on her claims of racial discrimination based on workplace harassment and intentional infliction of emotional distress. Under the facts, the court, however, refused to recognize plaintiff's prima facie tort claim, which the trial court properly dismissed.

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