Dustin' Off Hoffman v. Parade Publications

Last August we reported on several court decisions expanding the scope and application of the New York City Human Rights law. In one such case, Hoffman v. Parade Publications,¹ the New York Appellate Division, First Department had ruled that a Georgia-based employee had standing to contest his separation under the New York State and City discrimination statutes because the layoff decision was made at the company's New York City headquarters. The intermediate appellate court rejected a line of authority requiring an impact within the City (or New York State)² and held that a non-resident plaintiff need only allege that the discriminatory decision was made in New York to invoke the protection of state and local law.³