McCoy v. Premier Home Healthcare
NEW YORK COUNTY
Justice Joan Madden
Premier Home Healthcare moved for dismissal of the complaint, arguing employee McCoy previously released all claims against it in a federal court action. A magistrate judge partially dismissed McCoy's religious and disability bias claims, and continued the case regarding her race bias claim. A settlement was reached, and the record reflected that McCoy believed it intended to cover her litigation expenses and several years of back pay. McCoy began this action seeking damages of $1 million for breach of contract, asserting she did not agree to waive her right to sue Premier for unlawful dismissal. She claimed she was advised by the Equal Employment Opportunity Commission that she could sue Premier in state court. The court found the settlement and release made on the record in open court barred McCoy from relitigating any claims within the release, and granted dismissal. Also, it noted the documentation she received from the EEOC explicitly stated she may assert a claim in either federal or state court, not both. Thus, any claim to vacate the stipulation based on McCoy's confusion about the impact of the settlement to bring further claims must be made to the magistrate judge who approved the settlement.