Hostile Work Environment Claim Dismissed Against Federal Reserve Bank of New York

In Nguedi v. The Federal Reserve Bank of New York, 16-cv-636, 2019 WL 1083966 (S.D.N.Y. March 7, 2019), the court, inter alia, granted defendant’s motion for summary judgment on plaintiff’s hostile work environment claim.

From the decision:

The [New York City Human Rights Law] “is not a ‘general civility code.’ ” Mihalik, 715 F.3d at 110 (citing Williams v. N.Y.C. Housing Autb., 872 N.Y.S. 2d 27, 40-41 (App. Div. 1st Dep’t 2009)). “The plaintiff still bears the burden of showing that the conduct is caused by a discriminatory motive. It is not enough that a plaintiff has an overbearing or obnoxious boss. [He] must show that [he] has been treated less well at least in part ‘because of [his protected characteristic].’ ” Id. Plaintiff has made it clear that he believes these events took place, and that he believes he was targeted “simply because [he is] a Black man and solely based on race” 56.1 ¶ 26. However, he failed to produce evidence of the context of these alleged events, statements from other employees who witnessed the alleged events, or any other evidence beyond his own speculations from which the Court could infer a discriminatory animus motivating these actions (even assuming, arguendo, that they took place). Nor has Plaintiff even claimed that Mrs. Crouch or any other NY Fed employee ever made a facially discriminatory statement. In sum, there is no evidence upon which a reasonable jury could conclude that Plaintiff was treated less well, and even assuming arguendo that he was treated less well, there is no evidence upon which a reasonable jury could conclude that that any ill treatment he endured “was because of” his membership in a protected class.”