Discrimination Claims Fail Where Non-Resident Cannot Demonstrate Impact Within New York

Hoffman v. Parade Publications, et al., 15 N.Y.3d 285 (N.Y. App., July 1, 2010) – In this case, an employee who did not live or work in New York brought claims for age discrimination under the New York State Human Rights Law (NYSHRL) and the New York City Human Rights Law (NYCHRL) following his termination. Although the employee did not service any accounts in New York, he argued that New York courts had jurisdiction because he attended quarterly meetings in New York, the company’s contracts were negotiated in New York, and the decision to terminate him was made in New York. The state high court disagreed, holding that both the NYSHRL and the NYCHRL require a non-resident to plead and prove that the alleged discriminatory action had an impact in New York.