January 2026

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In Petrie v. New York State Office of Mental Health Central New York Psychiatric Center, No. 6:22-CV-123 (ECC/ML), 2026 WL 161198 (N.D.N.Y. Jan. 21, 2026), the court, inter alia, denied defendants’ motion for summary judgment on plaintiff’s hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. From the decision:…

Read More Title VII Hostile Work Environment Sexual Harassment Claim Survives Summary Judgment
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In Duckett-Holmes v. Planned Parenthood of Greater New York, Inc., No. 159488/2024, 2026 WL 93691 (N.Y. Sup. Ct. Jan. 05, 2026), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s hostile work environment claim. This decision illustrates the basic principles governing the pleading of such a claim: In order to state a claim for…

Read More Hostile Work Environment Claim Dismissed; “Bare Legal Conclusions” Insufficient to State a Claim
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In Rojo v. Lakeview Sec. & Investigations, Inc., No. 24-CV-5729 (JPO), 2026 WL 83909 (S.D.N.Y. Jan. 12, 2026), the court granted plaintiff’s motion for default judgment on her sex discrimination claims under the New York State and City Human Rights Laws. From the decision: A party’s default is deemed to constitute a concession of all…

Read More Default Judgment on NYSHRL and NYCHRL Sex Discrimination Claims Awarded
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In Cahn v. Chapler, 2026 NY Slip Op 50029(U) (Sup. Ct. NY Cty. Jan. 9, 2026), the court granted in part, and denied in part, defendants’ motion to dismiss plaintiff’s defamation claims. The court explained and summarized the law as follows: Defamation is defined as the making of a false statement of fact which tends…

Read More Defamation Claims, Arising From Instagram Posts Regarding Affair, Survive Dismissal
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In Ellis-Yancey v. Midwest Block & Brick/Quikrete Company, No. 4:25-CV-00822-JMB, 2026 WL 113595 (E.D. Mo. Jan. 14, 2026), the court, inter alia, dismissed plaintiff’s claims under Title VII of the Civil Rights Act of 1964, since they were not administratively exhausted at the U.S. Equal Employment Opportunity Commission. From the decision: Plaintiff’s claims in her…

Read More Race/Color/Gender Discrimination Claims Dismissed, as Not Administratively Exhausted at the EEOC
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In White v. Children’s Network of Southwest Florida LLC, No. 2:24-CV-00697-KCD-NPM, 2026 WL 98768 (M.D. Fla. Jan. 14, 2026), the court, inter alia, granted defendants’ motion to dismiss plaintiff’s hostile work environment claim. From the decision: As for the hostile work environment claim, employers can be liable when, despite not taking any tangible adverse action,…

Read More Age-Based Hostile Work Environment (ADEA( Claim Dismissed; “Old” Comments Insufficient to State a Claim
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In Poteat v. CP Development et al, No. 24-3290, 2026 WL 93129 (3d Cir. Jan. 13, 2026), the U.S. Court of Appeals for the Third Circuit affirmed a lower court’s granting of defendants’ motion to dismiss plaintiff’s claims of race discrimination and hostile work environment under 42 U.S.C. § 1981. The court summarized the facts,…

Read More Third Circuit Affirms Dismissal of Race Discrimination Claims Asserted Under 42 U.S.C. § 1981
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In Evseroff v. Scripps Media, Inc., No. 150375/2020, 2026 WL 95490 (N.Y. Sup. Ct. Jan. 06, 2026), the court, inter alia, granted defendants’ motion for summary judgment on plaintiff’s claim under Labor Law § 201-d. This claim arises from plaintiff’s termination following a Facebook post with a photo of the World Trade Center in the…

Read More Court Dismisses Discrimination Claim Arising From Facebook Post
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In Dorio v. Cmty. Hous. Mgmt. Corp. et al, No. 62784/2025, 2026 WL 90179 (N.Y. Sup. Ct. Jan. 8, 2026), the court, inter alia, granted defendants’ motion to dismiss plaintiff’s hostile work environment claim asserted under the New York State Human Rights Law. Among other things, plaintiff alleged that she was forced to endure a…

Read More Court Dismisses Scent-Based Hostile Work Environment Claim
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In Samah v. Takeda Pharmaceuticals U.S.A., Inc., No. 1:25-CV-10158-JEK, 2026 WL 63399 (D. Mass. Jan. 8, 2026), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s race-based hostile work environment claims. From the decision: Counts 5 and 9 assert that Takeda violated Title VII and Chapter 151B, respectively, by subjecting Samah to a racially…

Read More Race-Based Hostile Work Environment Claims Survive Dismissal
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