In Williams v. NYC DSS-HRA, No. 101114/2024, 2025 WL 1810234 (N.Y. Sup Ct, New York County July 01, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s age-based hostile work environment claim under the New York City Human Rights Law.
From the decision:
Plaintiffs also attempt to plead a hostile work environment under the NYCHRL, but this claim fares no better. A NYCHRL hostile-environment claim requires unequal treatment on account of a protected characteristic (i.e. actual bias)]; see Massaro v Department of Educ. of the City of N.Y., 121 AD3d 569, 570 [1st Dept 2014]). Plaintiffs’ allegations — that they were not properly trained, not given building access, assigned heavy caseloads and an alleged stalker co-worker — do not include any racial, gender, or other protected animus. They do not allege that any supervisor treated them worse because of a protected status. Indeed, they rely entirely on workplace frustration and inter-personal issues, not discrimination. Courts have uniformly dismissed NYCHRL hostile-environment claims where no protected-class nexus is pleaded (see e.g., Zabar v N.Y. City Dep’t of Educ., 18 Civ. 6657, 2020 U.S. Dist. LEXIS 83840, at *14 [SDNY May 12, 2020][dismissing hostile work environment claims where plaintiff failed to link the alleged misconduct to protected class]). Because Plaintiffs fail to allege any facts showing discrimination, their hostile work environment claim must be dismissed as well.
The court also dismissed plaintiff’s fraudulent inducement, discrimination, and whistleblower claims.