9 N.Y.3d 367 (2007)

Executive Law § 296 discrimination claims against a school district are subject to the one-year statute of limitations outlined in Education Law § 3813 (2-b), notwithstanding any other law providing a longer period.

Summary

Jennifer Amorosi sued the South Colonie Independent Central School District, alleging discrimination based on maternity leave in violation of Executive Law § 296. The Court of Appeals addressed whether the three-year statute of limitations for discrimination claims generally applies, or the one-year limit in Education Law § 3813 (2-b) specific to actions against school districts. The Court held that the one-year statute of limitations applied. The plain language of Education Law § 3813 (2-b) dictates a one-year limit for actions against school districts, superseding the general three-year limit for discrimination claims. Therefore, Amorosi’s claim was time-barred.

Facts

Jennifer Amorosi was hired as a temporary part-time guidance counselor in July 1999, becoming full-time in January 2001 with a three-year probationary period for tenure consideration. She took maternity leave in January 2002, returning in September 2002. Her probationary period was extended to June 2004 by agreement. While initial reviews were favorable, her July 2003 review indicated performance concerns. She took a second maternity leave in October 2003, returning in December 2003, after which she received a negative review and was allegedly asked to resign. She resigned in January 2004, effective June 2004. Amorosi claimed she became aware of the school district’s discriminatory practices in early 2005.

Procedural History

Amorosi initiated proceedings on September 7, 2005, seeking leave to file a late notice of claim, alleging discrimination. Supreme Court granted leave, applying a three-year statute of limitations. The Appellate Division reversed, holding that Education Law § 3813 (2-b) provides a one-year statute of limitations and the Supreme Court lacked the discretion to grant leave to file a late notice of claim since the proceeding was commenced more than one year after the cause of action arose. The Court of Appeals granted leave to appeal.

Issue(s)

Whether the one-year statute of limitations in Education Law § 3813 (2-b) applies to discrimination claims brought under Executive Law § 296 against a school district, or whether the general three-year statute of limitations for discrimination claims applies.

Holding

No, because the clear and unambiguous language of Education Law § 3813 (2-b) provides that, notwithstanding any other provision of law providing a longer period of time in which to commence an action or special proceeding, no action or special proceeding shall be commenced against any school district more than one year after the cause of action arose.

Court’s Reasoning

The Court reasoned that Education Law § 3813 (2-b) clearly and unambiguously dictates a one-year statute of limitations for actions against school districts. The Court emphasized that when statutory language is clear, it must be given effect, and courts should not resort to rules of construction to broaden a statute’s scope when the words are unequivocal. The Court distinguished prior cases (Koerner and Murphy) that applied a three-year statute of limitations to discrimination claims, noting those cases did not involve the application of Education Law § 3813. The Court also addressed and distinguished two appellate division cases, Lane-Weber and Stoetzel, noting that neither decision involved the specific application of Education Law § 3813 (2-b) to an Executive Law § 296 claim. The Court stated, “[D]espite any provision for a longer statute of limitations, such as the three-year statute of limitations in CPLR 214 (2), as urged by petitioner, the one-year limitation prescribed in Education Law § 3813 (2-b) should govern discrimination claims against a school district.” The court found that because the legislature is presumed to be aware of existing law, the lack of an exception for discrimination claims in Education Law § 3813 (2-b), similar to the exception for tort claims, indicated a deliberate intent to subject such claims to the one-year statute of limitations. The Court acknowledged the apparent contradiction with the policy of eliminating employment discrimination but deferred to the clear statutory language.