January 2026

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In Garcia v. ECPI Univ. LLC, No. 2:25-CV-245, 2026 WL 66749 (E.D. Va. Jan. 8, 2026), the court held that plaintiff alleged a “sexual harassment dispute” under the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 (EFAA), and thus denied defendant’s motion to compel arbitration of plaintiff’s claim under Title IX…

Read More Sexual Harassment Claim Stated Under Title IX; Motion to Compel Arbitration Denied Under EFAA
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In Draghi v. New York City Department of Education, No. 24-CV-2920 (EK)(MMH), 2026 WL 73970 (E.D.N.Y. Jan. 9, 2026), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s claim of hostile work environment asserted under the Americans with Disabilities Act (ADA). From the decision: To allege a hostile work environment, “a plaintiff must show…

Read More Disability-Based Hostile Work Environment Claim, Asserted Under ADA, Dismissed
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In Panchumarthi v. Tech Mahindra, No. 4:24-CV-01017-SDJ-BD, 2025 WL 3687142 (E.D. Tex. Dec. 15, 2025), the court held that the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act (EFAA) did not apply to plaintiff’s claims of discrimination (as opposed to sexual harassment). From the decision: Although the EFAA carves out some sex-discrimination claims,…

Read More Sexual Harassment Not Alleged; EFAA Did Not Apply to Sex Discrimination Claims
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In Lindsey v. Citigroup Global Markets, Inc., No. 23-CV-10166 (ALC)(SN), 2026 WL 63219 (S.D.N.Y. Jan. 8, 2026), in which plaintiff alleges claims of hostile work environment, gender discrimination, sexual assault, and retaliation, the court ruled on defendant’s motion to compel plaintiff to produce documents in response to various discovery requests. One issue addressed by the…

Read More Court Denies Motion to Compel Disclosure of Romantic Relationships in Sexual Harassment Case
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In Goldzweig v. Consolidated Edison Co. of New York, Inc., No. 25-0089-CV, 2026 WL 21005 (2d Cir. Jan. 5, 2026), the U.S. Court of Appeals for the Second Circuit, inter alia, affirmed the court’s award of summary judgment to defendant on plaintiff’s retaliation claims asserted under Title VII of the Civil Rights Act of 1964,…

Read More 2nd Circuit Vacates Summary Judgment Dismissal of NYC Human Rights Law Retaliation Claim
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In Ramirez v. City of New York, No. 24-CV-1061 (AS), 2026 WL 18678 (S.D.N.Y. Jan. 2, 2026), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s retaliation (but not disability discrimination) claim under the Rehabilitation Act. From the decision: The test for retaliation under the Rehabilitation Act has four parts: (1) the…

Read More Retaliation Claim, Based on Denial of Accommodations Following Filing of Lawsuit, Survives Summary Judgment
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In Thompson v. Foundever, No. 2:24-CV-771-RAH, 2026 WL 25450 (M.D. Ala. Jan. 5, 2026), the court, inter alia, held that plaintiff failed to plead retaliation claims under Title VII of the Civil Rights Act of 1964 and the Americans with Disabilities Act (ADA). This decision illustrates the level of specificity courts seek when assessing such…

Read More Retaliation Claims Dismissed; Protected Activity Insufficiently Alleged
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In Vines v. Aron Sec. Inc., No. 156409/2025, 2025 WL 3231742 (N.Y. Sup. Ct. Nov. 12, 2025), the court granted plaintiff’s motion for default judgment against the individual defendant on her claims of sex discrimination, sexual harassment, and retaliation. This decision provides an instructive overview of what a plaintiff must demonstrate to secure a default…

Read More Court Grants Motion for Default Judgment on Sex Discrimination, Sexual Harassment, and Retaliation Claims
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On December 19 2025, New York Governor Kathy Hochul signed the “Trapped at Work Act.” This law, which is effective immediately, adds a new Article 37 to the New York Labor Law, beginning with section 1050. Its stated purpose is to prohibit reimbursement clauses or promissory notes as a condition of employment. The law’s text…

Read More NY Governor Signs “Trapped at Work Act”
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In Keenan v. Bloomberg L.P., 2025 NY Slip Op 07224 (N.Y. App. Div. 1st Dept. Dec. 23, 2025), the court affirmed the lower court’s denial of defendant’s motion to dismiss plaintiff’s complaint alleging employment discrimination (including on disparate treatment and disparate impact theories). As to plaintiff’s disparate treatment claims, the court explained: Initially, we reject…

Read More Age, Sex Discrimination Claims Sufficiently Alleged Against Bloomberg L.P.
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