Plaintiff has also asserted two other claims under the City's Human Rights Law.
The complaint's seventh cause of action alleges that each defendant violated Admin.
Code § 8-107(19), which provides that "[i]t shall be an unlawful discriminatory
practice for any person to coerce, intimidate, threaten or interfere with, or attempt to
coerce, intimidate, threaten or interfere with, any person in the exercise or enjoyment of,
or on account of his or her having aided or encouraged any other person in the exercise
or enjoyment of, any right granted or protected pursuant to this section."
Threats are required to state a claim for violation of Admin Code § 8-107(19)
(Montanez v New York City Housing Authority, 5 AD3d 314, 315 [1st Dept
2004]). If "plaintiff does not allege that any of her putative employer's supervisors or
employees threatened or intimidated her or took any action besides requesting her
transfer, her claim against that employer for interference with a protected right must be
dismissed" (Artis v Random House, supra, 34 Misc 3d at 867). Based on
the foregoing this cause of action must be dismissed against all defendants, for plaintiff
does not allege that anyone threatened her.
The eighth cause of action alleges that defendants violated Admin. Code §
8-107(13), which makes it "an unlawful discriminatory practice (i) for any person to
discriminate against, boycott or blacklist" members of protected categories engaged in
various commercial activities..., or (ii) for any person willfully to do any act or refrain
from doing any act which enables any such person to take such action" (Scott v
Massachusetts Mutual Life Ins. Co., supra, 86 NY2d at 434). This section of
the City's Human Rights law, commonly known as the "Arab Boycott Law" because it