In Roberson v. New York City Health and Hospitals Corp., No. 151841/2023, 2024 WL 4957306 (N.Y. Sup Ct, New York County Nov. 30, 2024), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s claims of hostile work environment asserted under the New York State and City Human Rights Laws.
From the decision:
Here, Roberson alleges that defendants contributed to a hostile work environment based on her gender, race, and disability. According to the complaint, Roberson alleges that each time she expressed her concerns that her salary was based upon her race, she experienced a backlash of isolation that affected her ability to do her work. Although some of the incidents alleged in her complaint might amount to petty slights and inconveniences, taken together, (including being ignored and disregarded by Albertson), this court finds that these allegations are sufficient to support a claim of a hostile work environment. On a motion to dismiss, the court must accept plaintiff’s claims as true and resolve all reasonable inferences in her favor. Furthermore, employment discrimination cases are generally reviewed under notice pleading standards, and the First Department will not dismiss a claim outright due to lack of specificity. Thus, for example, it is not fatal to Roberson’s claim that she does not allege the details of Grinberg’s salary. It would, therefore, be premature, on this motion to dismiss, for this court to find that Roberson has no chance of making out a claim of hostile work environment under the SHRL or the CHRL. Accordingly, defendants’ motion to dismiss on this ground is denied.
This decision, as such, is instructive as to what allegations courts deem sufficient to make out