1 Analyses of this case by attorneys

  1. La Grande v. DeCrescente Distributing Co., Inc., Nos. 08-3010, 09-1789 (2d Cir. Mar. 23, 2010)

    Outten & Golden LLPMarch 23, 2010

    Denial of training on-the-job may constitute a materially adverse employment action for a disparate treatment claim:"Training is a benefit of employment that receives protection under Title VII. See 42 U.S.C. § 2000e-2(d); see also Holtz v. Rockefeller & Co., Inc., 258 F.3d 62, 76-79 (2d Cir. 2001) (concluding that summary judgment was improperly granted to defendant on plaintiff's failure-to-train claim under the Age Discrimination in Employment Act). Further, liberally construing the complaint, it is plausible that the DeCrescente Company's alleged action was a materially significant disadvantage with respect to the terms of La Grande's employment, particularly if the training was 'part of the job' and barring him from the training diminished his material responsibilities or opportunities."