Appellate Division of the Supreme Court of the State of New York December 27, 2011 (Ehmann v. Good Samaritan Hospital Medical Center)

To support a prima facie case of age discrimination under the Human Rights Law, the plaintiff must demonstrate (1) that she is a member of the class protected by the statute; (2) that she was actively or constructively discharged; (3) that she was qualified to hold the position from which she was terminated; and (4) that the discharge occurred under circumstances giving rise to an inference of