April 2025

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In Johnson v. 212 Fremont Sandusky Wine & Spirit, LLC, 2025 WL 843390(N.D.Ohio March 18, 2025), the court ruled on defendant’s motion for summary judgment on plaintiffs’ claims of hostile work environment sexual harassment asserted under Title VII of the Civil Rights Act of 1964 (as well as Ohio stae law). As to two plaintiffs,…

Read More Hostile Work Environment Sexual Harassment Claim Survives Summary Judgment; Alleged Harassment Was “Direct and Physical”
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In Khurana v. City of New York, No. 152921/2024, 2025 WL 1085410 (N.Y. Sup Ct, New York County Apr. 10, 2025), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s claim of hostile work environment under the New York City Human Rights Law (NYCHRL). From the decision: Under the NYCHRL, a plaintiff claiming a…

Read More Hostile Work Environment Claim Sufficiently Alleged; Plaintiff Claimed She Was Denied Benefits Offered to Able-Bodied Employees
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In Khurana v. City of New York, No. 152921/2024, 2025 WL 1085410 (N.Y. Sup Ct, New York County Apr. 10, 2025), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s claim of disability discrimination under the New York City Human Rights Law (NYCHRL). From the decision: To state a claim of disability discrimination under…

Read More NYCHRL Disability Discrimination Claim Survives Dismissal; Denial of Overtime, Promotion Was Sufficiently Disadvantageous
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In Arizzo v. Ethicon, Inc., No. 159122/2023, 2025 WL 1047066 (N.Y. Sup Ct, New York County Apr. 03, 2025), the court denied plaintiff’s motion to amend their complaint to add hostile work environment claims under the New York State and City Human Rights Laws against a proposed defendant (Ethicon US). In sum, the court held…

Read More NYS & NYC Human Rights Laws Held Inapplicable to NJ Employer of NJ Resident
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In Knox v. CRC Management Co., LLC, No. 23-121, 2025 WL 1057862 (2d Cir. April 9, 2025), the U.S. Court of Appeals for the Second Circuit, inter alia, vacated a lower court Order dismissing plaintiff’s claims, on summary judgment, of race- and national origin-based termination. From the decision: Knox alleges that Clean Rite’s decision to…

Read More Race, National Origin Discrimination Claims Survive Summary Judgment, 2nd Circuit Finds
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A recent decision, Perrotte v. Bloomberg L.P. et al, No. 2024-03283, 4061, 451470/20, 2025 N.Y. Slip Op. 02046, 2025 WL 1033707 (N.Y.A.D. 1 Dept., Apr. 08, 2025), the New York Supreme Court, Appellate Division, First Department illustrates how courts assess discovery disputes in an employment discrimination case. From the decision: Supreme Court providently exercised its…

Read More First Department Assesses Discovery of Internal Complaints, Cell Phone in Sexual Harassment Case
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In Menos v. Uncle Nearest, Inc. et al, 22-CV-1449 (PKC) (PK), 2025 WL 917347 (E.D.N.Y. March 25, 2025), the court, inter alia, denied defendants’ motion for summary judgment on plaintiff’s sexual harassment claims asserted under the New York State and City Human Rights Laws. From the decision: Plaintiff’s sexual harassment claims rely predominantly on three…

Read More Sexual Harassment Claims Survive Summary Judgment; Allegations Include Touching, Inquiries Into Personal Life, Late-Night Text Messages
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In Gathers v. K & K Family Ventures, LLC, Case No. 2:24-cv-4422-RMG, 2025 WL 892773 (D.S.C. March 24, 2025), the court declined to adopt a Magistrate’s Report & Recommendation, and held that plaintiff sufficiently alleged a constructive discharge claim, arising from alleged sexual harassment. From the decision: The Court declines to adopt the portion of…

Read More Constructive Discharge Claim, Based on Sexual Harassment, Sufficiently Alleged
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In Swinburne v. City of New York, No. 153793/2024, 2025 WL 990587 (N.Y. Sup Ct, New York County Mar. 28, 2025), the court denied defendant’s motion to dismiss plaintiff’s retaliation claim asserted under the New York City Human Rights Law. From the decision: Under [NYCHRL], it is unlawful to retaliate against an employee for opposing…

Read More Retaliation Claim Sufficiently Alleged; Transfer/Demotion Followed Request for Vaccine Exemption
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In Beatty v. NYC District Council of Carpenters and Joiners of America, 1:23-cv-02126 (ALC) (SN), 2025 WL 963307 (S.D.N.Y. March 31, 2025), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s sex-based hostile work environment claims asserted under Title VII of the Civil Rights Act of 1964, the New York State Human…

Read More Sex-Based Hostile Work Environment Claims Survive Summary Judgment; Evidence Included Appearance-Related Jokes and Comments
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