In Shah v. Wilco Systems, Inc., 27 A.D.3d 169, 806 N.Y.S.2d 553 (1st Dept 2005), the Appellate Division, First Department held that, when a nonresident seeks to invoke the coverage of the New York City Human Rights Law (NYCHRL), he or she must establish that the impact of the discriminatory act was felt by the plaintiff in New York City.
The First Department stated that, even if the termination decision had happened in New York City, the NYCHRL would not apply since the impact on the plaintiff occurred outside of New York City.
"The locus of the decision to terminate plaintiff is of no moment. What is significant is where the impact is felt." Id. at 176.