June 2024

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In Riggins v. Town of Berlin, 2024 WL 2972896 (2d Cir. June 13, 2024), the U.S. Court of Appeals for the Second Circuit vacated the lower court’s summary judgment dismissing plaintiff’s complaint alleging a hostile work environment sexual harassment. In this case, in sum, plaintiff alleges, among other things, that her employer (the Town of…

Read More Hostile Work Environment Sexual Harassment Claim Resurrected From Summary Judgment as to Insufficiency of Employer’s Response to Alleged Harassment
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In Barcellos v. The City of New York, No. 157998/2018, 2024 WL 2941863 (N.Y. Sup Ct, New York County June 4, 2024), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s claim of disparate treatment under the New York City Human Rights Law.[1]The court addressed plaintiff’s “hostile work environment” claim separately; I…

Read More NYCHRL Sexual Harassment Claim Survives Dismissal; Issues of Fact Existed as to Whether Plaintiff Was “Treated Less Well” Because of Her Gender
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In Barcellos v. The City of New York, No. 157998/2018, 2024 WL 2941863 (N.Y. Sup Ct, New York County June 4, 2024), the court, inter alia, denied defendant’s motion for summary judgement on plaintiff’s claims of hostile work environment sexual harassment asserted under the New York State and City Human Rights Laws. As to the…

Read More Hostile Work Environment Sexual Harassment Claims Survive Summary Judgment; Allegations Include Supervisor’s Sex-Based Comments, Remarks, and/or Gestures
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In Tohidi v. City of Reading Police Department, No. 5:24-cv-0591, 2024 WL 3015514 (E.D.Pa. June 13, 2024), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s claim of disability discrimination asserted under the Americans with Disabilities Act (ADA). From the decision: The City asserts that Counts I and V (disability discrimination) should be dismissed…

Read More Disability Discrimination Claim Asserted by Plaintiff With Tourette’s Syndrome, Survives Dismissal
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In Brown v. Valvoline, LLC et al, 2024 WL 2946099 (S.D.Tex. June 11, 2024), the court, inter alia, granted defendants’ motion for summary judgment on plaintiff’s claims of race-based hostile work environment asserted under Title VII of the Civil Rights Act of 1964 and § 1981. From the decision: The facts presented to the Court…

Read More N-Word, “Knuckle Heads” Comments Did Not Give Rise to Actionable Hostile Work Environment, Court Holds
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In Thompson v. Shutterstock, Inc. et al, 23-CV-4155 (JGLC), 2024 WL 2943813 (S.D.N.Y. June 10, 2024), the court, inter alia, denied defendant Shutterstock’s motion to dismiss plaintiff’s claim of retaliation asserted under 42 USC § 1981. Here, plaintiff based his retaliation claim on comments alleged to have been made by Shutterstock’s chief HR officer (Garfield)…

Read More Retaliation Claim, Under 42 USC § 1981, Sufficiently Alleged Against Shutterstock
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In Trotter v. National Football League, 23-cv-8055 (JSR), 2024 WL 2952637 (S.D.N.Y. June 12, 2024), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s claim of retaliation asserted under 42 USC § 1981. From the decision: The sufficiency of Trotter’s retaliation claim turns on whether he has adequately alleged that he engaged in some protected…

Read More Retaliation Claim Sufficiently Alleged Against NFL, Court Finds
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In Thompson v. The City of New York, No. 525109/2022, 2024 WL 2941866 (N.Y. Sup Ct, Kings County June 11, 2024), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s race-based discrimination claims asserted under the New York State and City Human Rights Laws. (The court also held that plaintiff sufficiently pleaded a hostile…

Read More Race-Based Discrimination Claims, Based on Alleged Disparate Discipline, Sufficiently Alleged Under the NYS and NYC Human Rights Laws
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In Thompson v. The City of New York, No. 525109/2022, 2024 WL 2941866 (N.Y. Sup Ct, Kings County June 11, 2024), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s hostile work environment claim under the New York City Human Rights Law. While the court held that plaintiff did not sufficiently allege a hostile…

Read More Race-Based Hostile Work Environment Claim Sufficiently Alleged Under NYC Human Rights Law
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In Williams v. Breaking Ground Housing Development Fund Corporation et al, 22-cv-8715 (AS), 2024 WL 2882122 (S.D.N.Y. June 6, 2024), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s retaliation claims asserted under Title VII of the Civil Rights Act of 1964, the New York State Human Rights Law, and the New York City…

Read More Retaliation Claims, Based on Termination Following Complaint of Sexual Harassment, Survive Dismissal
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