In Taylor v. Baylar, No. 151924/2020, 2020 WL 6435450, 2020 N.Y. Slip Op. 33610(U) (N.Y. Sup Ct, New York County Oct. 22, 2020), the court denied defendants’ motion to dismiss plaintiff’s claims for pregnancy discrimination under the New York State and City Human Rights Laws.
As to the state law claim, the court held:
Plaintiff’s complaint alleges that she is female, a member of a protected class, and was pregnant at the time of her termination. She has stated that she was qualified for her job, that Defendant Baylar, the president of the company, recruited her to work for Defendant Hudson Furniture, Inc. because he was aware of her strong work ethic and ability to procure sales, that she was a leading sales person at the time she was terminated, and that she had procured almost $2 million in sales during her first eight months. Additionally, Plaintiff alleges that despite these qualifications, within seven days of informing Defendant Baylar that she was pregnant she was terminated. These allegations at the pleading stage are sufficient to meet the fair notice standard (see Montgomery v Elrac, Enterprise Holdings, Inc., No. 25814/2016E, 2019 WL 4929889, at *4 [NY Sup Ct 2019] [“to properly plead a discrimination claim, plaintiff need not plead specific facts; it is sufficient that the plaintiff give notice of the nature of the claim”]; also Petit v Dep’t of Educ. of City of New York, 177 AD3d 402, 403, 113 NYS3d 30, 32  [court reinstated discrimination claims dismissed on a motion to dismiss for failure to state a cause of action because “employment discrimination cases are . . . generally reviewed under notice pleading standards”]).
Because plaintiff stated a claim under the New York State Human Rights Law, she necessarily stated a claim under the (comparatively broader) New York City Human Rights Law.