A New York appellate court recently upheld a decision to dismiss a discrimination lawsuit against a manager at Community Urgent Care, P.C. The ruling affects how employment discrimination claims can be brought against individual managers under state and city human rights laws.

The case, Choudhry v. Community Urgent Care, P.C., was filed by Shoaib Mohamad Choudhry, who alleged that he faced discrimination based on race, religion, and national origin. The court's decision, issued on November 12, 2026, clarifies the legal standards for holding individual employees accountable under New York's human rights laws.

This ruling is significant for employees and employers alike, as it outlines the limitations of individual liability in discrimination cases. The court's decision may influence future cases involving claims of discrimination in the workplace.

Background

Shoaib Mohamad Choudhry initiated the lawsuit against Community Urgent Care, P.C., and several individuals, including John Lieberman, in July 2022. Choudhry claimed he experienced discrimination due to his race, religion, and national origin, which he argued violated both the New York State Human Rights Law and the New York City Human Rights Law.

Following the filing of the complaint, Lieberman moved to dismiss the claims against him, arguing that the allegations did not meet the legal standards required to hold him personally liable. The Supreme Court of Kings County agreed with Lieberman, leading to Choudhry's appeal to the Appellate Division.

The Ruling

The Appellate Division, Second Department, reviewed the case and affirmed the lower court's decision to dismiss the claims against Lieberman. The ruling emphasized that under New York law, individual employees, even those with managerial titles, are generally not considered employers for the purposes of discrimination claims.

The court ruled, "A corporate employee, though the employee has a title as an officer and is the manager or supervisor of a corporate division, is not individually subject to suit with respect to discrimination under the New York State Human Rights Law."

The judges, including Colleen D. Duffy, Lara J. Genovesi, Deborah A. Dowling, and James P. McCormack, concurred with the decision. They noted that Choudhry's amended complaint did not sufficiently allege that Lieberman was liable as an employer or that he engaged in any discriminatory conduct.

The court also highlighted that individual liability could only arise if a person aided or abetted discriminatory actions, which was not established in this case. The judges stated that the amended complaint failed to provide adequate facts supporting such claims.

Impact

This ruling has significant implications for how discrimination cases are pursued in New York. It clarifies that employees cannot hold individual managers liable under the state's human rights laws unless they can prove that those individuals engaged in discriminatory conduct or retaliated against them.

The decision may deter some individuals from filing claims against managers, as it sets a higher standard for proving individual liability. It also reinforces the idea that businesses, rather than individual employees, are primarily responsible for discriminatory practices in the workplace.

What's Next

Choudhry may seek further legal recourse, including the possibility of appealing to a higher court. However, details about any potential appeal or related cases were not available in the court filing.