September 2025

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In Varney v. Health Carousel, LLC, Case No. 1:24-cv-624, 2025 WL 2605783 (S.D.Ohio Sept. 9, 2025), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s pregnancy/lactation-related hostile work environment constructive discharge claim asserted under Title VII of the Civil Rights Act of 1964. This decision underscores that, when evaluating hostile work environment claims, it…

Read More Pregnancy/Lactation-Related Hostile Work Environment Claims Survive Dismissal
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In Cuellar v. Christie’s Inc., No. 155077/2023, 2025 WL 2429617 (N.Y. Sup Ct, New York County Aug. 21, 2025), the court, inter alia, granted defendants’ motion to dismiss plaintiff’s discrimination claims asserted under the New York State and City Human Rights Laws. The court summarized, and applied, the law as follows: A cause of action…

Read More Discrimination Claims Dismissed; In Context, “Lazy” Was Neutral & Not Used in a Racially-Derogatory Way
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In Colin S.K. Correa v. U.S. General Services Administration et al, 2025 WL 2532727 (S.D.N.Y. Sept. 2, 2025), the court, inter alia, dismissed plaintiff’s non-federal law discrimination claims. From the decision: Plaintiff cannot bring state law claims for employment discrimination under the New York City or New York State Human Rights Laws because Title VII…

Read More Court Dismisses Federal Employee’s NYS and NYC Human Rights Law Claims
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In Maresca v. Richmond University Medical Center, 22-CV-6636(EK)(MMH), 2025 WL 2482010 (E.D.N.Y. Aug. 28, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s religious-based hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: Maresca alleges that “Mr. Musselwhite, head lawyer for HR” condescendingly told…

Read More Vaccine-Related Religion-Based Title VII Religious-Based Hostile Work Environment Claim Dismissed
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In Santana v. Shook Hardy & Bacon, 2025 WL 2521193 (S.D.N.Y. Sept. 2, 2025), the court granted defendants’ motion to dismiss plaintiff’s discrimination, hostile work environment, and retaliation claims asserted under Title VII of the Civil Rights Act of 1964, the New York State Human Rights Law, and the New York City Human Rights Law.…

Read More Alleged Unprofessional Treatment Insufficient to State Claims for Discrimination, Hostile Work Environment and Retaliation
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In Williams v. Family Health International d/b/a FHI 360 et al, 2025 WL 2506580 (D.D.C. Sept. 2, 2025), the court, inter alia, held that plaintiff did not state a claim for hostile work environment under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 1981, and the District of Columbia Human Rights…

Read More Hostile Work Environment Claims Dismissed; Alleged Actions Were “Ordinary, Albeit Unpleasant”, Workplace Conduct
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In Garcia v. Westhampton Primary Care, 2:23-cv-4319 (NJC) (ST), 2025 WL 2494357 (E.D.N.Y. Aug. 30, 2025), the court, inter alia, held that plaintiff plausibly alleged claims of hostile work environment under Title VII of the Civil Rights Act of 1964 and the New York State Human Rights Law. The court summarized, and applied, the law…

Read More Hostile Work Environment, Retaliatory Hostile Work Environment Claims Survive Dismissal
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In Fisher v. Valley Stream Central High School District et al, 2025 WL 2467046 (E.D.N.Y. Aug. 27, 2025), the court, inter alia, held that plaintiff sufficiently stated a cause of action for retaliation under Title VII of the Civil Rights Act of 1964. Specifically, plaintiff alleged that defendants suspended her pay and benefits, in retaliation…

Read More Title VII Retaliation Claim, Based on Complaints About Alleged Excessive Workload Due to Status as Unmarried Woman With Children, Survives Dismissal
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For many of us, Labor Day is the unofficial farewell to summer. It’s a three-day weekend filled with barbecues, beach trips, and one last chance to enjoy the warm weather before the crisp autumn air arrives. But amidst the fun and relaxation, it’s easy to forget the true meaning of this holiday. Labor Day is…

Read More Happy Labor Day 2025
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