In Peter v. The Churchill School and Center, No. 156979/2025, 2026 WL 2430831 (N.Y. Sup. Ct. Aug. 11, 2026), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s hostile work environment claim under the New York City Human Rights Law.
From the decision:
To state a claim for hostile work environment under the NYCHRL, a plaintiff must allege that she was treated less well than other employees because of a protected characteristic, considering the totality of the circumstances (Williams v New York City Hous. Auth., 61 AD3d 62, 78-80 [1st Dept 2009]). Liability does not extend to petty slights or trivial inconveniences. Neither the NYSHRL nor the NYCHRL functions as a “general civility code,” and occasional offensive comments or routine disciplinary scrutiny, without more, do not rise to the level of a hostile work environment.
Once the time-barred conduct is excluded, what remains is plaintiff’s account of the disciplinary warnings issued between September 2023 and January 2024 and the denials of her accommodation requests. Discipline and heightened scrutiny of an employee’s performance, standing alone, do not constitute conduct rising above petty slights or trivial inconveniences, and, to the extent plaintiff’s accommodation denials form the basis of a separate harassment theory, that conduct is addressed above as part of her disability discrimination and accommodation claims. Plaintiff identifies no timely comment or conduct directed at her race, national origin, or disability that approaches the severity or pervasiveness necessary to support a hostile work environment claim.
(Citations omitted.)
Based on this, the court held that dismissal was warranted.