By: Scott D. Wilson
A White former high school psychologist failed to prove a coworker’s comment calling her a “Karen” qualified as race-based discrimination, a federal judge ruled.
Elizabeth D’Aiello, who worked at Freeport High School in New York, didn’t experience “severe or pervasive” enough treatment for a reasonable jury to conclude she experienced a hostile work environment, Judge Joan M. Azrack wrote Tuesday for the US District Court for the Eastern District of New York.
The judge granted the school, Freeport School District, and individual defendants summary judgment on all the suit’s federal claims. She remanded D’Aiello’s claims under New York law back to state court.
The suit is part of a growing tide of workplace discrimination cases brought by White employees in recent years, bolstered by the Equal Employment Opportunity Commission’s renewed focus on discrimination against majority groups.
D’Aiello worked at the high school from 2004 until her resignation in 2024, according to the opinion. Her allegations center on a 2021 incident when a secretary said to her and another White woman, “Here comes Karen 1 and Karen 2.”
D’Aiello complained about the statement, leading school administrators to convene a meeting where the secretary apologized. Still, the meeting “began to devolve” and an assistant principal said, “This is not fairyland, Ms. D’Aiello, this is Freeport,” the opinion said.
In subsequent incidents, D’Aiello said the same assistant principal told her to lock her door during a school drill and told her she had “walked in the wrong door” when she was looking for a principal’s office, which she took as “verbally aggressive,” the opinion said.
Azrack found none of these incidents constitute a hostile work environment under Title VII of the 1964 Civil Rights Act as her complaint stated.
“Although the remarks may have been ‘unpleasant’ to her, that alone does not constitute a materially disadvantageous change in employment sufficient to qualify as an adverse action,” the judge added.
D’Aiello’s discrimination claims under the Americans with Disabilities Act also fail because she didn’t cite any adverse actions related to her hearing impairment beyond a single comment, Azrack wrote. Her retaliation claims fail because she didn’t show the school took any negative actions against her related to her complaints.
The judge remanded her remaining discrimination and retaliation claims under New York law back to state court.
The case is D’Aiello v. Freemont High Sch. , E.D.N.Y., No. 2:23-cv-00577, 10/20/26 .
