Henry v. Daytop Village, Inc.

42 F.3d 89 (2nd Cir. 1994)

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Nature of the Case

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Facts

Daytop’s (D) health plan provided health benefits to employee spouses only to the extent that a spouse’s own health plan would not cover medical expenses. To get reimbursement for spousal medical expenses, all of D’s employees were required to provide written documentation of a spouse’s health plan. Henry (P) sought and was granted reimbursement by D for medical expenses related to her husband. D’s investigation revealed that D had overpaid P $760.53 as a result of duplicative claims. When confronted, an argument ensued, and P was fired for employee misconduct. P sued claiming she was unlawfully fired under Title VII because she was a black female. She claimed that D’s misconduct allegations were a pretext for firing her as she had not misrepresented her husband’s medical coverage and white male employees received more lenient sanctions for similar conduct. D moved for summary judgment in that P’s allegations were inconsistent and included an admission that she did commit misconduct. The district court granted D’s summary judgment motion.