Hostile Work Environment Sufficiently Alleged; Allegations Included Comments, Thrown Objects, and Changed Locks

In a recent case, Palmer v. Cook, 2019 NY Slip Op 29240 (Sup. Ct. Qns. Cty. Aug. 5, 2019), the court, inter alia, held that plaintiff sufficiently stated a claim for hostile work environment under the New York City Human Rights Law.[1]As with many blog posts, here I have addressed only a subset of this lengthy and detailed decision; the reader is encouraged to review the decision in its entirety.

It found that plaintiff alleged “both a series of incidents … sufficiently continuous and concerted to have altered the conditions of her work environment” and that she was “treated less well than other employees because of her membership in a protected class”.

Specifically, in addition to various alleged comments (including defendant calling plaintiff a “whore” or “prostitute” for wearing a “sleeveless but professional … dress to work in the summertime”), plaintiff alleged, inter alia, that defendant “threw or destroyed small objects in fits of anger”, changed the locks on the office door upon plaintiff’s return from administrative leave, and removed plaintiff “from all of her work responsibilities”.

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1. As with many blog posts, here I have addressed only a subset of this lengthy and detailed decision; the reader is encouraged to review the decision in its entirety.