April 2025

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In Smith v. National Grid USA, 2:21-cv-6899 (NJC) (LGD), 2025 WL 1248676 (E.D.N.Y. April 30, 2025), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s race-based hostile work environment claims. From the decision: [T]here are numerous genuine disputes of material fact concerning Smith’s hostile work environment claims—under both the higher federal standard…

Read More Race-Based Hostile Work Environment Claims Survive Summary Judgment; Allegations Include “Shine Box” and “Monkey” Comments
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In McCardle v. District of Columbia, Case No. 19-cv-3637 (JMC), 2025 WL 1167956 (D.D.C., 2025), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s claim of age-based hostile work environment asserted under the Age Discrimination in Employment Act (ADEA). From the decision: The District argues that McArdle cannot establish a hostile work…

Read More Age-Based Hostile Work Environment Claim Survives Summary Judgment
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In Smart, Kathyann v. USA Labor for Hire, Inc., RC Global Energy Group, Inc., Oleg Tsimbler, No. 24-1791, 2025 WL 1217365 (2d Cir. April 28, 2025), the U.S. Court of Appeals for the Second Circuit, inter alia, affirmed the lower court’s denial of defendant’s motion for new trial or remittitur on plaintiff’s claims of hostile…

Read More 2nd Circuit Holds That Jury Properly Found Hostile Work Environment, Based on Racially Derogatory and Sexist Language,
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In Huaman v. United Airlines, Inc., No. 160784/2023, 2025 WL 1158984 (N.Y. Sup Ct, New York County Apr. 21, 2025), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s complaint asserting employment discrimination under the New York State and City Human Rights Laws. From the decision: Defendants’ motion to dismiss pursuant to CPLR 3211(a)(7)…

Read More Motion to Dismiss NYSHRL & NYCHRL Discrimination Claims Denied; “Impact” Test Satisfied
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In Wright v. White Plains Hospital Medical Center, No. 2023-05430, 64135/19, 2025 N.Y. Slip Op. 02371, 2025 WL 1173144 (N.Y.A.D. 2 Dept., Apr. 23, 2025), the court affirmed the award of summary judgment dismissing plaintiff’s claims of pregnancy discrimination under Title VII of the Civil Rights Act of 1964 and the New York State Human Rights…

Read More Pregnancy Discrimination Claims Properly Dismissed, 2nd Department Holds
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In Cohen v. Arnot Health, Inc. et al, 2025 WL 1197854 (2d Cir. April 25, 2025), the U.S. Court of Appeals for the Second Circuit affirmed the lower court’s award of summary judgment on plaintiff’s age discrimination claim asserted under the Age Discrimination in Employment Act (ADEA) and the New York State Human Rights Law…

Read More Age Discrimination Claims Properly Dismissed, Absent Adverse Employment Action
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In Browne v. New York State Department of Corrections and Community Supervision, 2025 WL 1177958 (2d Cir. April 23, 2025), the U.S. Court of Appeals for the Second Circuit affirmed the district court’s award of summary judgment to the defendant on plaintiff’s claim of a race-based hostile work environment under Title VII of the Civil…

Read More Hostile Work Environment Claim Properly Dismissed; Allegedly “Racially Offensive” Poems Insufficient
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In Yuliano v. Cent. Park West Orthodontics P.C., No. 161370/2019, 2025 WL 1168160 (N.Y. Sup Ct, New York County Apr. 22, 2025), the court denied defendants’ motion for summary judgment on plaintiff’s hostile work environment claim asserted under the New York City Human Rights Law. From the decision: The City HRL must be “construed liberally…

Read More Citing Alleged Instruction to “Sexualize” Plaintiff’s Appearance, Court Allows Hostile Work Environment Claim to Proceed
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In Noh v. Admarketplace, Inc., 24 Civ. 2107 (ER), 2025 WL 965882 (S.D.N.Y. March 28, 2025), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s sex- and race-based hostile work environment claims asserted under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 1981, and the New York State and City…

Read More Hostile Work Environment Claim, Based on Race and Sex, Survive Dismissal
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In Huber v. TIAA, 2025 WL 1139131 (W.D.Va. April 17, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s hostile work environment claim in violation of Title VII of the Civil Rights Act of 1964. In sum, plaintiff alleged that defendant engaged in religious discrimination by failing to accommodate her request for a…

Read More Title VII Religion-Based Hostile Work Environment Claim Dismissed
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