Appellate Court Grants Employer’s Motion to Dismiss Claims of Discrimination Under New York City Human Rights Law Brought by Non-Profit Org Due to Lack of Legal Injury

In Athenaeum Blue & White (R.A.), Inc. v American Studies Assn., Inc., the Appellate Division, Second Department held that plaintiff, Athenaeum Blue & White (R.A.), failed to allege an injury in fact sufficient to make out a claim of discrimination under the New York City Human Rights Law and New York State Human Rights Law. The pleadings alleged that after joining the American Studies Association ("ASA"), Athenaeum Blue & White (R.A.) ("Athenaeum"), an Israeli organization, was made to feel unwelcome because of national origin when ASA posted a boycott of Israeli educational institutions on its website, which plaintiff alleged violated the public accommodation provisions of the laws. In the lower court's opinion, the court said the plaintiff had not sufficiently…


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