context: Second Circuit precedent involving individual liability under Title VII of the Civil Rights Act of 1964 further supports the conclusion that an individual may not be held liable in her or his personal capacity under the ADA.
citation_a.signal: see also
citation_a.identifier: 941 F.Supp. 388, 395
citation_a.parenthetical: "[t]he Second Circuit's reasoning in Tomka is equally applicable to the question of individual liability under the ADA as well"
citation_a.sentence: See Tomka v. Seiler Corp., 66 F.3d 1295, 1321 (2d Cir.1995) (holding that individual defendants may not be held liable for violations under Title VII); see also Lane v. Maryhaven Center of Hope, 944 F.Supp. 158, 162 (E.D.N.Y.1996) (finding as a matter of law that the ADA does not provide for a cause of action against an employer’s individual agents or employees); Cerrato v. Durham, 941 F.Supp. 388, 395 (“[t]he Second Circuit’s reasoning in Tomka is equally applicable to the question of individual liability under the ADA as well”).
citation_b.signal: see
citation_b.identifier: 66 F.3d 1295, 1321
citation_b.parenthetical: holding that individual defendants may not be held liable for violations under Title VII
citation_b.sentence: See Tomka v. Seiler Corp., 66 F.3d 1295, 1321 (2d Cir.1995) (holding that individual defendants may not be held liable for violations under Title VII); see also Lane v. Maryhaven Center of Hope, 944 F.Supp. 158, 162 (E.D.N.Y.1996) (finding as a matter of law that the ADA does not provide for a cause of action against an employer’s individual agents or employees); Cerrato v. Durham, 941 F.Supp. 388, 395 (“[t]he Second Circuit’s reasoning in Tomka is equally applicable to the question of individual liability under the ADA as well”).