Richmond v. Sorensen

── Richmond v. Sorensen ── Case No.: 25-241 Court: Court of Appeals for the Second Circuit Date: April 01, 2026 Category: General 25-241-cv Richmond v. Sorensen UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT SUMMARY ORDER RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL. At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 1st day of April, two thousand twenty-six. PRESENT: DENNY CHIN, RAYMOND J. LOHIER, JR., STEVEN J. MENASHI, Circuit Judges. ------------------------------------------------------------------ JULIA RICHMOND, Plaintiff-Appellant, v. No. 25-241-cv ALAN J. SORENSEN, Defendant-Appellee. ------------------------------------------------------------------  FOR PLAINTIFF-APPELLANT: MICHAEL H. SUSSMAN, Sussman & Associates, Goshen, NY FOR DEFENDANT-APPELLEE: KELLIE E. LAGITCH, Chief Assistant County Attorney, for Richard B. Golden, Orange County Attorney, Goshen, NY Appeal from a judgment of the United States District Court for the Southern District of New York (Vincent L. Briccetti, Judge). UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that the judgment of the District Court is AFFIRMED. Plaintiff Julia Richmond appeals from the January 7, 2025 judgment entered in the United States District Court for the Southern District of New York (Briccetti, J.) granting summary judgment in favor of Defendant Alan J. Sorensen on Richmond’s claim of sex discrimination under 42 U.S.C. § 1983. We assume the parties’ familiarity with the underlying facts and the record of prior proceedings, to which we refer only as necessary to explain our decision to affirm. In October 2016, Richmond began serving as Deputy Commissioner of Planning for the Orange County Department of Planning and Development. Sorensen became Commissioner of the Department in March 2020, and he 2 terminated Richmond’s employment in December 2021, prompting the current § 1983 action. “We review de novo a district court’s decision to grant summary judgment, construing the evidence in the light most favorable to the party against whom summary judgment was granted and drawing all reasonable inferences in that party’s favor.” Horn v. Med. Marijuana, Inc., 80 F.4th 130, 135 (2d Cir. 2023) (citation modified). “A plaintiff who claims sex discrimination in public employment in violation of the Fourteenth Amendment may bring suit pursuant to § 1983.” Naumovski v. Norris, 934 F.3d 200, 212 (2d Cir. 2019); see Feingold v. New York, 366 F.3d 138, 159 (2d Cir. 2004). Unlike sex discrimination claims brought under Title VII, for which plaintiffs are required to satisfy “a lessened causation standard,” a plaintiff “pursuing a claim for employment discrimination under § 1983 . . . must establish that the defendant’s discriminatory intent was a ‘but-for’ cause