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:
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