The Restoration Act of 2005 amended the New York City Human Rights Law (NYCHRL) to require that discrimination claims under the city law be held to a separate and more liberal standard than state and federal anti-discrimination laws. In the wake of the act, New York courts struggled to distinguish NYCHRL claims from their federal and state counterparts. In response, the Appellate Division, First Department, in Williams v. New York City Housing Authority took the opportunity to “construe” the act and the standard to be applied to claims under the NYCHRL.1

In an opinion by Justice Rolando Acosta, the First Department explained that the NYCHRL “explicitly requires an independent liberal construction in all circumstances” and that an analysis of NYCHRL claims “must be targeted to understanding and fulfilling what the statute characterizes as the city HRL’s uniquely broad and remedial purposes, which go beyond those of counterpart State or federal civil rights laws.”

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