In Izuogu v. Credit Agricole Corporate and Investment Bank, New York, 24 Civ. 4329 (DEH), 2025 WL 2806683 (S.D.N.Y. Oct. 2, 2025), the court, inter alia, granted defendants’ motion to dismiss plaintiff’s hostile work environment claims under Title VII of the Civil Rights Act of 1964 and 42 U.S.C. 1981.
From the decision:
To establish a hostile work environment, a “plaintiff must show that the harassment was sufficiently severe or pervasive to alter the conditions of the victim’s employment and create an abusive working environment.” This requires the plaintiff to show that the alleged misconduct was “severe or pervasive enough to create an objectively hostile or abusive work environment,” and that she “also subjectively perceive[d] that environment to be abusive.” “To decide whether the threshold has been reached, courts examine the case-specific circumstances in their totality and evaluate the severity, frequency, and degree of the abuse.” “In short, a plaintiff alleging a hostile work environment must demonstrate either that a single incident was extraordinarily severe, or that a series of incidents were sufficiently continuous and concerted to have altered the conditions of her working environment.” “But isolated incidents or episodic stray remarks are not sufficiently continuous and concerted in order to be deemed pervasive.” Moreover, a plaintiff must show that “the conduct that he claims created a hostile environment was the result of his race [or other protected characteristic].”
This claim faces numerous obstacles. For one, CACIB denies that it was Mr. Izuogu’s employer, although Mr. Izuogu argues that it was. CACIB also argues that the four incidents described by Mr. Izuogu do not rise to the level of an actionable hostile work environment, which means a “workplace [that] was so severely permeated with discriminatory intimidation, ridicule, and insult that the terms and conditions of her employment were thereby altered.” The Court agrees. The complaints to Mr. Izuogu’s supervisor and the gossip and rude emails described in the Complaint simply do not rise to the level of “an objectively hostile or abusive work environment.”
Second, Mr. Izuogu does not allege that any of the remarks, gossip, or false complaint that he allegedly endured referenced his race or national origin in any way. Nor does he allege that similarly situated persons outside of his protected class(es) were treated differently than he was. With respect to causation, he simply alleges his own conclusion and a single similarly conclusory statement by “his supervisor Georgia Gordon [that CACIB’s] agents were hostile to [him]” because they were “obviously motivated by racial and nationality bias against [him].”81 But this is too conclusory to establish causation.82 “Courts consistently dismiss similar cases where the plaintiff makes only conclusory allegations with regard to causation.”
(Cleaned up.)
Based on this, the court dismissed plaintiff’s federal hostile work environment claims.