June 2025

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In Esqueda, M.D., Jonathan v. NYU Langone Hospitals, 2025 WL 1785870 (SDNY June 27, 2025), the court, inter alia, granted defendants’ motion for summary judgment on plaintiff’s race- and national origin-based hostile work environment claims asserted under Title VII of the Civil Rights Act and 42 U.S.C. § 1981. After summarizing the black-letter law applicable…

Read More Race, National Origin-Based Hostile Work Environment Claims Dismissed; Alleged Mocking of Accent Insufficient
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In Zimpfer v. Hilbert College, Case No. 1:21-cv-231, 2025 WL 1758266 (W.D.N.Y. June 25, 2025), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s hostile work environment claim asserted under the (amended) New York State Human Rights Law. From the decision: As to the NYSHRL hostile-work-environment claim, Defendants cite authority indicating that…

Read More Hostile Work Environment Claim Sufficient to Withstand Summary Judgment Under Newly-Amended NYS Human Rights Law
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In Trump v. CASA, Inc., 2025 WL 1773631 (U.S. 2025), the U.S. Supreme Court ended the so-called “universal injunction” – here, an order issued by a single U.S. District Court to stop nationwide implementation of an Executive Order. While this case arose from challenges to the president’s Executive Order ending “birthright citizenship,” this decision does…

Read More U.S. Supreme Court Limits “Universal Injunctions” in “Birthright Citizenship” Case
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In Anderson v. The City of New York, No. 155791/2023, 2025 WL 1756499 (N.Y. Sup Ct, New York County June 25, 2025), the court, inter alia, plaintiff did not state a cause of action for retaliation under the New York City Human Rights Law. From the decision: In his second cause of action, plaintiff brings…

Read More Retaliation Claim Dismissed; Complying With Drug Screening Was Not “Protected Activity” Under The NYC Human Rights Law
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In Collins, Sam v. Federal Express Corporation, 2025 WL 1764809 (2d Cir. June 26, 2025), the U.S. Court of Appeals for the Second Circuit, inter alia, affirmed the lower court’s dismissal of plaintiff’s hostile work environment claims as being time-barred. From the decision: We also agree that Collins’ hostile-work-environment claims are time-barred. A hostile work…

Read More Hostile Work Environment Claims Against FedEx Properly Dismissed as Time-Barred, 2nd Circuit Holds
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In Cherner v. CF Bankshares Inc., 24-CV-02812 (PMH), 2025 WL 1745864 (S.D.N.Y. June 23, 2025), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s gender discrimination claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: Title VII “makes actionable any form of sex-based compensation discrimination.” Lenzi v. Systemax,…

Read More Male Plaintiff Sufficiently Alleges Gender Discrimination Under Title VII of the Civil Rights Act of 1964
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In Simmons v. Baccarat Inc., No. 651516/2023, 2025 WL 1735659 (N.Y. Sup Ct, New York County June 23, 2025), the court, inter alia, granted plaintiff’s motion to dismiss plaintiff’s claims of hostile work environment and sexual harassment under the New York State and City Human Rights Laws. From the decision: The Moving Defendants correctly assert…

Read More Hostile Work Environment, Sexual Harassment Claims Dismissed; Evidence Indicated That Plaintiff Participated in “Sexually Themed” Text Messages
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In Winfrey v. The City of New York, No. 160719/2024, 2025 WL 1446806 (N.Y. Sup Ct, New York County May 20, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s claims of race discrimination under the New York State and City Human Rights Laws. From the decision: To plead a prima facie case…

Read More Race Discrimination Claims Dismissed; Alleged Alcohol Consumption on Duty, Rather Than Race, Was Basis For Termination
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In Kay v. Banchik, No. 654454/2023, 2025 WL 1707867 (N.Y. Sup Ct, New York County June 17, 2025), the court, inter alia, held that plaintiff failed to state age and gender discrimination claims under the New York State and City Human Rights Laws. From the decision: Defendants’ motion to dismiss Plaintiff’s remaining allegations for failure…

Read More Age, Sex Discrimination Claims, Asserted Under the NYS and NYC Human Rights Laws, Dismissed
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In Stanley v. City of Sanford, Fla., 2025 WL 1716138 (U.S. June 20, 2025), the U.S. Supreme Court interpreted the Americans with Disabilities Act (ADA) and addressed the question of whether that statute “reaches discrimination against retirees who neither hold nor desire a job whose essential tasks they can perform with reasonable accommodation.” The Court…

Read More Supreme Court: Retiree’s ADA Disability Discrimination Claim Properly Dismissed
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