Wanda Wilson has worked for JPMorgan Chase for eighteen years as a secretary. It was in that period that she learned to tune out racist remarks. Wanda was once asked, “Wanda, do you mind if I tell a Black joke?” by a coworker.

Although she didn’t like Black people in general, Ms. Wilson was told by another employee that she made an exception for her. Ms. Wilson didn’t think there was anything to be angry about or whine about.

However, things took a terrible turn in 2016 when Ms. Wilson was intimidated and mistreated by a new coworker. She then launched a lawsuit against Jamie Dimon, the CEO of JPMorgan. It is said that Ms. Wilson realized that she did not have the same status as her white coworkers for the first time. She voiced her disapproval to JPMorgan officials but claimed that the bank’s response destroyed her faith in her business.

In March 2016, Ms. Wilson started working in the audit department as an executive administrative assistant. This position is quite popular among secretaries because it includes overseeing the work of a single senior executive.

Around the same time, Janet Jarnagin was designated as a team leader under Ms. Wilson’s supervisor. A publicly accessible resume stated that among Janet Jarnagin’s duties as a mid-level executive was helping the audit department with report and presentation preparation.

The lawsuit claims that throughout the next six months, Janet Jarnagin started giving Ms. Wilson instructions to hang jackets, purchase coffee and lunch, or handle requests from visitors to the department, including photocopying. 

The Prohibition of Janet Jarnagin 

Defendant JPMorgan Chase Bank, N.A. (“JPMorgan”) employed Wanda Wilson, an African American woman, for more than twenty years. Wilson alleges that JPMorgan discriminated against her in violation of local and state statutes.

Under the New York State Human Rights Law (“NYSHRL”), N.Y. Exec. Law 290 et seq., and the New York City Human Rights Law (“NYCHRL”), N.Y.C., Wilson specifically pursues claims for a hostile work environment, racial discrimination, and retaliation.

Admin. Code 8-101 and so forth. Wilson’s claims were dismissed with permission to resubmit the matter in an earlier Opinion and Order. Following that, Wilson submitted the Second Amended Complaint (“SAC”) in effect. ECF No. 77 (“SAC”).

Wilson’s amended claims are currently being challenged by JPMorgan under Federal Rules of Civil Procedure Rule 12(b)(6). Also ECF No. 79. For the grounds listed below, the motion is partially granted and partially denied. 

The Case’s Context for Janet Jarnagin 

The prior Opinion and Order from the Court, which is assumed and won’t be repeated here, provides the pertinent background information. WL 918770 (2021), pp. *1-3. Rather, the Court will just highlight the key differences between the previous Complaint and the current SAC. However, the Court needs to settle two preliminary matters first.

First, JPMorgan argues that because the SAC’s major charges “directly contradict” the information in Wilson’s earlier complaints, the Court should ignore them. Def.’s Memo, ECF No. 80, at 12; also see Id. at 8–10, 11–14. Should the plaintiff “blatantly change” her story in a way that “directly contradicts” her prior pleadings, the court has the authority to reject factual claims made in an updated complaint.

Since the differences between Wilson’s prior files and the SAC do not constitute the kind of “blatant” disagreements that have compelled other courts to drop charges in subsequent pleadings, the second, “more benevolent option,” is appropriate in this instance. 580 F.Supp.2d (Kermanshah) at 266. Wilson now, according to JPMorgan, “relies on wholly new allegations of explicit, ‘overt’ race-based conduct.” 

Wilson recounts interactions with Janet Jarnagin, an Executive Director who was assigned to serve as Team Leader under Managing Director Paul Jensen when Wilson was his Executive Administrative Assistant.  The SAC specifically claims that:

In her complaint, Ms. Wilson stated that Janet Jarnagin had only made these requests of her because she was the only Black secretary in the region. She tried to get away from herself. The complaint claims that Janet Jarnagin made fun of her for trying to build a “Mexican wall” out of a pile of files on her desk after she rearranged her workspace such that the two women could no longer see each other without hindrance.

The lawsuit claims that Ms. Wilson complained about Janet Jarnagin to their manager, who told her to solve the problem on her own. She then complained about Janet Jarnagin micromanaging her and disparaging her work to a human resources representative. JPMorgan’s Mr. Evangelisti stated that the bank had begun investigating Ms. Wilson’s claims.

According to two people who are aware of the investigation, bank employees questioned those who were close to Ms. Wilson and Janet Jarnagin. The investigators concluded that Janet Jarnagin had treated Ms. Wilson rudely. However, the people concluded that Janet Jarnagin’s actions were not motivated by race because she had previously treated non-Black personnel poorly. According to Mr. Evangelisti, the decisions made by the authorities were “based on information provided by Ms. Wilson at the time.” 

CONCLUSION

In her complaint, Ms. Wanda Wilson claims that Ms. Janet Jarnagin treated her unfairly at JP Morgan Chase Bank. Ms. Janet Jarnagin worked for the bank as an executive director.

While these incidents claim systemic and widespread prejudice against banks, Ms. Wilson’s lawsuit paints a more complex picture of interactions between coworkers that occasionally have racist connotations.

It illustrates how challenging it is to corroborate allegations of racism in the workplace, even when an investigation is conducted by a company. This is particularly true when there isn’t any openly racist speech or actions, such as wearing blackface or using racial slurs.

Board and management reporting is Janet Jarnagin’s area of expertise as an executive consultant in the financial sector. Analyzing corporate data both qualitative and quantitative and compiling it into succinct, engaging executive presentations is Janet’s line of work. She is considered an authority in the field by many.

She also assists in the stabilization and improvement of business processes before offering advice to companies on how to improve them both globally and locally. These days, Janet Jarnagin resides in New York City.

JPMorgan’s move to dismiss is partially granted and partially denied for the reasons mentioned above. In particular, the Court rules that while Wilson’s allegations of retaliation must be and are dismissed, her claims of a hostile work environment and race discrimination under the NYCHRL and NYSHRL cannot be dismissed. 

JPMorgan has three weeks to submit a response to Wilson’s remaining claims unless the court directs otherwise. An initial pretrial meeting will be scheduled by the Court by separate Order to be issued today.