July 2024

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In Pennetti v. The City of New York, No. 154367/2023, 2024 WL 3345017 (N.Y. Sup Ct, New York County June 24, 2024), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s hostile work environment claims. From the decision: Defendant’s motion to dismiss Plaintiff’s hostile work environment claim is denied. Under the State HRL, a…

Read More Hostile Work Environment Claims Survive Dismissal; Allegations Included Yelling, Demeaning, and Threatening to Terminate Older Male Employees
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In Riggs v. Akamai Technologies et al, No. 1:23-CV-06463-LTS, 2024 WL 3347032 (S.D.N.Y. July 8, 2024), the court, inter alia, denied defendants’ motion to dismiss, and held that plaintiff sufficiently alleged, a hostile work environment sexual harassment claim under Title VII of the Civil Rights Act of 1964 and the New York State and City…

Read More Hostile Work Environment Sexual Harassment Claims Survive Dismissal; Allegations Included Sex Stereotyping and Comments About Sex Life
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In Anderson v. Street, 104 F.4th 646 (7th Cir. June 13, 2024), the court affirmed the lower court’s award of summary judgment on plaintiff’s hostile work environment sexual harassment claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: Anderson claims that Mott Street is liable for creating a hostile…

Read More Hostile Work Environment Sexual Harassment Claim Properly Dismissed; Alleged Conduct (Including “Bitch” Comment) Was Not “Severe or Pervasive”
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In Lazarine v. Allied Universal Event Services, No. 153143/2023, 2024 WL 3312472 (N.Y. Sup Ct, New York County July 01, 2024), the court granted defendant Columbia University School of Nursing’s motion to dismiss plaintiff’s employment discrimination claims against it. In sum, plaintiff worked as a security guard for defendant Allied Universal and was assigned to…

Read More Finding Elements of “Joint Employment” Lacking, Court Dismisses Employment Discrimination Claims Against Columbia University
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In Silverthorne v. The City of New York, No. 507047/2023, 2024 WL 3312436 (N.Y. Sup Ct, Kings County July 05, 2024), the court granted the defendant’s motion to dismiss plaintiff’s claims of race/gender discrimination and hostile work environment asserted under the New York State and City Human Rights Laws. From the decision: Accepting the facts…

Read More Race/Gender Discrimination, Hostile Work Environment Claims Dismissed; “Ambiguous” Allegations as to “Angry Black Woman” Comment Insufficient
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In Oman v. State of Hawai’i Department of Education, No. 21-00462 MWJS-WRP, 2024 WL 3090229 (D.Hawai’i June 21, 2024), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s claim of sexual harassment asserted under Title VII of the Civil Rights Act of 1964. In sum, plaintiff, a public middle school counselor (Oman)…

Read More Title VII Hostile Work Environment Sexual Harassment Claim Survives Summary Judgment; Allegations Included Masturbation in Plaintiff’s Presence
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In Lasarge v. Fastex Logistics, Inc., Case No. 23 C 14836, 2024 WL 3011359 (N.D.Ill., June 14, 2024), the court, inter alia, held that plaintiff plausibly alleged sexual harassment under Title VII of the Civil Rights Act of 1964. From the decision: Title VII and IHRA make it a civil rights violation for an employer…

Read More Title VII Hostile Work Environment Sexual Harassment Claim Sufficiently Alleged; Separation From Alleged Harasser Not Dispositive
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Recently, the U.S. Supreme Court held, in Erlinger v. United States, 2024 WL 3074427 (U.S. June 21, 2024), that a criminal defendant is entitled, under the Fifth and Sixth Amendments, to have a jury unanimously determine beyond a reasonable doubt whether his past offenses were committed on separate occasions for purposes of the Armed Career…

Read More A Brief History of Trial by Jury in the United States, Per the Supreme Court
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In Minor v Essence Ventures, LLC, No. 533765/2023, 2024 N.Y. Slip Op. 50758(U), 2024 WL 3212243 (NY Sup Ct Kings Cty, June 23, 2024), the court denied defendant’s motion to dismiss plaintiff’s disability discrimination claim asserted under the New York State Human Rights Law. This decision is instructive as to how courts assess the sufficiency…

Read More NYSHRL Disability Discrimination Claim Survives Dismissal; Inference Supported by Termination 8 Days After Disclosure of Disability
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In Nelson v. WW Intern., Inc., No. 155745/2020, 2024 WL 32208823 (N.Y. Sup Ct, New York County June 28, 2024), the court, inter alia, granted defendant’s motion for summary judgment on plaintiff’s caregiver status discrimination claim under the New York City Human Rights Law. From the decision: Defendant’s motion for summary judgment dismissing Plaintiff’s claims…

Read More Citing “Stray Remarks” Doctrine, Court Dismisses Caregiver Status Discrimination Claim
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