2025

In Calvert v. Allosource, No. 24-CV-03165-CYC, 2025 WL 3550963 (D. Colo. Dec. 11, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s hostile work environment claim. From the decision: The plaintiff asserts that the defendant created a hostile work environment because he reported discrimination and unsafe working conditions. ECF No. 9 at 6.…

Read More Hostile Work Environment Claim Dismissed; Complaint Lacked Sufficient Detail
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In White v. Board of Trustees of the University of Arkansas, No. 4:25-CV-00702-BSM, 2025 WL 3527401 (E.D. Ark. Dec. 9, 2025), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s hostile work environment claim asserted under the Americans with Disabilities Act (ADA). From the decision: Defendants’ motion to dismiss White’s ADA hostile work environment…

Read More ADA Hostile Work Environment Claim Survives Dismissal
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In Rizvi v. Loudoun County School Board, No. 1:25-CV-307-MSN-IDD, 2025 WL 3514256 (E.D. Va. Dec. 5, 2025), the court, inter alia, granted defendants’ motion to dismiss plaintiff’s hostile work environment claims based on age, race, color, national origin, and religion. From the decision: Defendant further seeks to dismiss Plaintiff’s claims of hostile work environment under…

Read More Age, Race, Color, National Origin, Religion-Based Hostile Work Environment Claims Dismissed
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In Risner v. Thomas E. Creek VA Med. Ctr., No. 2:24-CV-202-Z-BR, 2025 WL 2899903 (N.D. Tex. Oct. 10, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s claim of sexual harassment asserted under Title VII of the Civil Rights Act of 1964, on the ground that plaintiff failed to “exhaust administrative remedies.” From…

Read More Sexual Harassment Claims Not Administratively Exhausted at the EEOC, Court Holds
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In Myers v. Doherty, 2025 NY Slip Op 06550 (N.Y. App. Div. 1 Dept. Nov. 25, 2025), the court affirmed the lower court’s order granting defendants’ motion to dismiss plaintiff’s complaint alleging claims of employment discrimination, retaliation, and hostile work environment. From the decision: Plaintiff did not experience an adverse employment action when he was…

Read More Failure to Demonstrate Discriminatory Animus Dooms Discrimination, Retaliation, & Hostile Work Environment Claims, First Department Holds
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Yesterday, New York Governor Hochul signed the Reasonable Accommodation Anti-Retaliation Act (S3398/A4898), which amends the New York State Human Rights Law (specifically, section 296(7) of the New York Executive Law) to clarify that it shall be an unlawful discriminatory practice to retaliate against an individual for requesting a reasonable accommodation. In particular: This bill closes this…

Read More Governor Hochul Signs Reasonable Accommodation Anti-Retaliation Act (S3398/A4898)
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In Livingston-Willis v. Iberia Comprehensive Community Health Center Inc. et al, No. 6:25-CV-00954, 2025 WL 3457935 (W.D. La. Nov. 13, 2025), the court, inter alia, held that plaintiff failed to state a hostile work environment claim under Title VII of the Civil Rights Act of 1964. From the decision: In order to establish a hostile…

Read More Hostile Work Environment Claim Not Stated; Only “Passive” Conduct Alleged
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In Alfonzo Walker, Jr. v. Beau Rivage Resorts, LLC, No. 1:24CV386-LG-RPM, 2025 WL 346018 (S.D. Miss. Dec. 2, 2025), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s religious discrimination claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: Title VII makes it unlawful for employers “to discriminate…

Read More Muslim, Terminated For Placing a Religious Sign on Locker, Sufficiently Alleges Title VII Religious Discrimination Claim
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In Ghiorse v. John H. Cook, Jr. Painting Contractor, Inc. et al, No. 3:25-CV-1578 (BKS/MJK), 2025 WL 3465995 (N.D.N.Y. Dec. 2, 2025), the court, inter alia, recommended the the district court allow plaintiff’s hostile work environment claim under Title VII o the Civil Rights Act of 1964 to proceed against the entity defendant – but…

Read More Title VII Sex-Based Hostile Work Environment Claim Sufficiently Alleged; Status of Key Actor to be Clarified in Amended Complaint
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In Mildes v. Shriners Hosps. for Child., No. 2:23-CV-00356-SAB, 2025 WL 3176084 (E.D. Wash. Nov. 13, 2025), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s failure to accommodate disability claim under the Americans with Disabilities Act (ADA). From the decision: To establish a prima facie failure to accommodate claim under the…

Read More ADA Failure to Accommodate Claim Survives Summary Judgment
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