Joseph v. Metro. Museum of Art

3 Citing cases

  1. Ellis v. Univ. of Rochester

    19-CV-6380 CJS (W.D.N.Y. Feb. 8, 2024)   Cited 2 times

    There is no private right of action to sue under Title VI or Title IX for disparate impact discrimination. See, Joseph v. Metro. Museum of Art, 684 Fed.Appx. 16, 17 (2d Cir. 2017) (affirming dismissal of Title VI disparate-impact discrimination claim); see also, Klaneski v. Bristol Hosp., Inc., No. 3:22-CV-1158 (VAB), 2023 WL 4304925, at *4 (D. Conn. June 30, 2023) (“Although a private plaintiff may bring a claim under Title IX for instances of intentional discrimination, courts have held that a private right of action based on the alleged disparate impact of a policy on a protected group is not cognizable under Title IX.”)

  2. Am. Italian Women for Greater New Haven v. City of New Haven

    CIVIL 3:21-CV-01401 (JCH) (D. Conn. Jun. 3, 2022)   Cited 2 times

    In other words, AIW “concedes that [it] was given access, but t[akes] issue with the content on display” - or lack thereof - in the park. Joseph v. Metro. Museum of Art, 684 Fed.Appx. 16, 17 (2d Cir. 2017). “Accordingly, [AIW] fails to allege any denial of access or different treatment than other visitors, which is required to sustain a [section 2000a] claim.” Id.

  3. Bailey v. N.Y. Law Sch.

    16 Civ. 4283 (ER) (S.D.N.Y. Dec. 27, 2017)   Cited 8 times
    Dismissing NYSHRL § 296 discrimination claims, having found Title IX discrimination claims were insufficiently pleaded

    Moreover, even after viewing these allegations in the light most favorable to Plaintiff, she states at most that NYLS's gender discrimination impacts her more severely because of her race. Title VI only targets intentional discrimination, and cannot be invoked to redress disparate-impact discrimination. Joseph v. Metro. Museum of Art, 684 F. App'x 16, 17 (2d Cir. 2017) (citing Jackson v. Birmingham Bd. of Educ., 544 U.S. 167, 178 (2005)). Thus, the SAC fails to state a Title VI claim.