Davis v. N.Y.C. Dep’t of Edu., No. 14-1034 (2d Cir. 2015)Annotate this Case
Plaintiff filed suit against her employer, alleging a claim of discrimination under the Americans with Disabilities Act (ADA), 42 U.S.C. 12112-12117, and seeking damages. Plaintiff's claim is based on her employer’s decision to reduce her discretionary bonus after she was absent from work for four months. The district court granted summary judgment for the defendant. The court concluded that the district court erred in ruling that denial or reduction of a bonus could not constitute an adverse employment action solely because the employer had discretion whether to pay a bonus. The court further concluded that, despite this error, the district court correctly determined that, even if plaintiff established an adverse employment action, she failed to present evidence that would support the necessary finding of discriminatory motivation. Accordingly, the court affirmed the judgment.