Rojas v. Roman Catholic Diocese of Rochester
2011 U.S. App. LEXIS 20125, 660 F.3d 98, 113 Fair Empl. Prac. Cas. (BNA) 708 (2011)
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Rule of Law:
In rare circumstances, a court may grant summary judgment by disregarding a plaintiff's testimony where the plaintiff relies almost exclusively on their own account, that account is riddled with contradictions and inconsistencies, and the facts alleged are so implausible that no reasonable jury could find for the plaintiff.
Facts:
- Sandra Rojas was employed by the Roman Catholic Diocese of Rochester as its Coordinator for Hispanic Migrant Ministry from May 2004 to November 2006.
- Rojas's office was located at the Church of the Nativity, which was a separate corporate entity from the Diocese.
- Pastor Peter Enyan-Boadu was the pastor of the Church of the Nativity and was not an employee of the Diocese.
- Rojas's direct supervisor, employed by the Diocese, was Bernard Grizard.
- Rojas alleged that she was sexually harassed by Enyan-Boadu, which created a hostile work environment.
- Rojas's story regarding who her supervisor was and whether she specifically reported the sexual harassment to the Diocese changed multiple times throughout various legal proceedings.
- The Diocese terminated Rojas's employment on November 9, 2006.
Procedural Posture:
- Sandra Rojas sued the Roman Catholic Diocese of Rochester and Pastor Peter Enyan-Boadu in the United States District Court for the Western District of New York.
- Rojas alleged claims of sex discrimination (hostile work environment) and retaliation under Title VII and the New York State Human Rights Law.
- The defendants filed a motion for summary judgment, arguing there were no genuine issues of material fact for a jury to decide.
- The District Court granted the defendants' motion for summary judgment, dismissing Rojas's claims.
- Rojas, as plaintiff-appellant, appealed the District Court's grant of summary judgment to the United States Court of Appeals for the Second Circuit.
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Issue:
Does a district court err in granting summary judgment by disregarding a plaintiff's self-serving and internally contradictory testimony when that testimony constitutes the only evidence of a material dispute?
Opinions:
Majority - Per Curiam
No. A district court does not err by making a limited assessment of a plaintiff's testimony at the summary judgment stage in the rare circumstance where the plaintiff relies almost entirely on their own contradictory and incomplete testimony. The court reasoned that while it is improper to weigh evidence or assess credibility on a typical summary judgment motion, this case presented an extraordinary exception under the precedent of Jeffreys v. City of New York. Rojas’s case depended almost entirely on her own testimony, which was replete with plain inconsistencies regarding key issues, such as whether Enyan-Boadu was her supervisor and whether she had ever specifically complained of sexual harassment to the Diocese. Her later deposition testimony and affidavit directly contradicted her earlier sworn statements in complaints, interrogatories, and prior criminal trial testimony. Given these irreconcilable contradictions and the absence of any other corroborating evidence, the court concluded that no reasonable jury could find in her favor, and thus no 'genuine' issue of material fact existed.
Analysis:
This decision solidifies the 'sham affidavit' or Jeffreys exception to the general rule that courts must not weigh credibility at the summary judgment stage. It empowers district courts to scrutinize a non-moving party's testimony when it is the sole basis for their claim and is fraught with contradictions of their own prior sworn statements. The ruling serves as a barrier against plaintiffs attempting to defeat summary judgment by belatedly manufacturing factual disputes through testimony that contradicts earlier admissions. It underscores that for a factual dispute to be 'genuine' under Federal Rule of Civil Procedure 56, the evidence supporting it must be such that a reasonable jury could believe it, a standard that severely contradictory testimony fails to meet.
