In Armstrong v. Aura Healthcare, LLC, No. 3:24-cv-723 (VAB), 2025 WL 357839 (D.Conn. Jan. 31, 2025), the court, inter alia, held that plaintiff did not sufficiently allege a hostile work environment.
From the decision:
Ms. Armstrong alleges that she was subjected to an objectively hostile or abusive work environment, as she was subjected to hostile remarks by Mountainside employees and management, such as being called an “idiot” and “hyper verbal” and laughing at her, due to Plaintiff not getting the Covid-19 vaccine because of her asthma diagnosis, and then when she reported this disability discrimination and these hostile remarks, the Defendant took no corrective action to remedy the disability discrimination and hostile acts by Mountainside management and employees towards Plaintiff, and the Defendant failed to immediately document Plaintiff’s complaints of disability discrimination and the hostile work environment after she made them.
But case law within this Circuit establishes that sporadic comments, slurs, and jokes do not satisfy this hostile work environment] standard,” see Fletcher v. ABM Bldg. Value, No. 14 CIV. 4712 (NRB), 2018 WL 1801310, at *23 (S.D.N.Y. Mar. 28, 2018) (collecting cases) (finding that remarks like “black bitch,” “fucking idiot,” “these fucking people,” and unresponsive complaints were not enough to sustain a hostile work environment claim) aff’d, 775 F. App’x 8 (2d Cir. 2019); Augustin v. The Yale Club of New York City, 274 F. App’x 76, 77 (2d Cir. 2008) (“episodes of name-calling, inappropriate behavior by a supervisor, and other perceived slights, which, however regrettable, do not constitute a hostile work environment even if taken as true”).
[Citations, ellipses, internal bracketing and quotation marks omitted.]
The court concluded that, “in the absence of additional allegations to support her hostile work environment claim, the motion to dismiss will be granted as to the hostile work environment claims.”