On Thursday, Judge Oetken dismissed a Major League Baseball umpire’s discrimination claims under the Ohio Civil Rights Act, holding that the plaintiff could not seek relief under the conflicting laws of two different states based on a single course of employer conduct. The plaintiff alleged that the MLB discriminated against him on the basis of race and brought claims under Ohio and New York law.
Plaintiff argued that the “transitory nature” of his job meant that he is discriminated against in every state in which he works. However, because plaintiff challenged the same acts under both laws, Judge Oetken applied a choice of law analysis and found that the two state laws conflicted because Ohio permits punitive damages while New York does not. Judge Oetken held that New York had a greater interest in the litigation and dismissed the Ohio claims:
In this case, it is clear that New York’s concern for the issues raised in the pleadings outweighs Ohio’s. Both Defendants have a principal place of business in New York, a factor that gives New York a strong interest in the outcome of this suit. By comparison, Ohio’s interest is limited to Hernandez’s allegation that by not being made “crew chief, he is being discriminated against in many cities . . . including the city of Cincinnati, Ohio.” What Hernandez means, however, is that the “effects of the Defendants’ discriminatory conduct” have been felt in Ohio, as they have been in New York and numerous other states. Importantly, Hernandez does not allege that “Defendants’ decision[s] to not select him for: (1) crew chief, and (2) to umpire the World Series . . . were made in Ohio.” The locus of these challenged employment decisions—which is often crucial in a determination of state interest—has not been alleged here.
Thus, Ohio has no particular interest in this suit, especially compared to New York, which has a strong interest in enforcing employment law with respect to organizations headquartered within its boundaries. Following New York’s “state interest” test, it is evident that New York has both a stronger interest in disputes involving employers operating principally within its boundaries and far more contacts to the parties involved.