New York's Madison Square Garden and several of its employees received an icy reception in federal court when they attempted to have a lawsuit dismissed. In Prince v. Madison Square Garden, the Honorable Robert W. Sweet, Judge of the Southern District of the State of New York, summarily denied the defendants' application to end a "hostile work environment" claim brought against them by, Courtney Prince, a professional ice skater.
In the fall of 2002, Ms. Prince was selected by the Garden to be a member of "The Skaters," a group of ice-skating cheerleaders of the New York Rangers (a professional hockey team). In August of 2003, upon her promotion to team captain, Ms. Prince purports that certain of her superiors began to treat her (and other team members) in a sexually demeaning manner. Her complaint alleges that Jason Vogel (deputy director of public relations for the Rangers) and Ryan Halkett (director of game-day presentations for the Rangers) treated her and other "Skaters" as "sex objects" and fostered a sexually hostile work environment. Some sixteen examples of the conduct are outlined in her pleadings. They include allegations that:
The Garden and Halkett required Prince and other "Skaters" be "sexually alluring;"
Halkett informed Prince that a fellow "Skater's" breasts were too small and that the individual needed to "stuff her bra;"
Halkett made "unwelcome sexual remarks" to a "Skater" about her sex life and his;
Halkett made "disparaging remarks" about the "sexual morals" of another "Skater;"
Vogel made "unwelcome sexual advances and sexually assaulted" Prince and made such advances on other Garden employees;
Garden managers (including Halkett) required Prince and other "Skaters" to "fraternize" with management and to attend post-game parties and gatherings where "unwelcome sexual conversations" occurred; and
Garden managers and supervisors (including Vogel and Halkett) accompanied underage "Skaters" to bars and restaurants and purchased alcohol for them.The Court noted that on a motion to dismiss, a judge's function is not to assess whether a claimant can "prove" her case but whether the pleading sets forth a cognizable legal basis for relief. As Judge Sweet observed in his decision, the governing standard is whether the Defendants are afforded "adequate notice" of the claims against them and the grounds upon those claims are predicated. In order to determine whether Prince met this standard, the Court examined the legal framework of a hostile work environment case and outlined the elements as follows:
In order to state a cause of action for hostile work environment, Prince must allege that: (1) her workplace was permeated with conduct that was "sufficiently severe or pervasive to alter the conditions of her work environment;" and (2) "a specific basis exists for imputing the conduct that created the hostile environment to the employer." [citation omitted] The conduct in question "must be severe or pervasive enough to create an environment that 'would reasonably be perceived, and is perceived, as hostile or abusive.'" [citation omitted]Ultimately, the Court concluded that the facts, as alleged in the pleadings, satisfied these parameters and allowed Prince's case to survive procedural attack.
If Prince's allegations prove true, it might be time to tend the Garden, don't you think?
For a copy of the District Court's decision, please click on the following link:
Prince v. Madison Square Garden