Employment Law

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In Yelder v. Hegseth, 2025 WL 2373355 (8th Cir. 2025), the court, inter alia, affirmed the summary judgment dismissal of plaintiff’s hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: Here, Yelder argues that the following conduct constitutes severe or pervasive conduct: (1) Parker ripping up…

Read More Title VII Hostile Work Environment Claim, Though Based on Insensitive and Offensive Comments, Held Properly Dismissed
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In Niemotko v. Mount St. Mary Coll., 2025 NY Slip Op 04658 (N.Y. App. Div. 2 Dept. Aug. 13, 2025), the court, inter alia, affirmed the summary judgment dismissal of plaintiff’s hostile work environment claim asserted under the New York State Human Rights Law. From the decision: A plaintiff claiming a hostile work environment animated…

Read More Hostile Work Environment Claim Properly Dismissed, 2nd Dept. Holds
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In Smith v. Boehringer Ingelheim Pharmaceuticals, LLC, 2025 WL 2403042 (D.Conn. Aug. 19, 2025), the court granted the defendant’s motion to compel arbitration of plaintiff’s sex-based hostile work environment claim under Title VII of Civil Rights Act of 1964. Specifically, the court held that plaintiff’s claims did not implicate the protections of the Ending of…

Read More Sex-Based Hostile Work Environment Not Plausibly Alleged, EFAA Did Not Apply, Arbitration Compelled
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In Dupray v. NY Loft, LLC and Ana Sternberg, Civil Action No. 25-229, 2025 WL 2393375 (D.N.J. August 18, 2025), the court denied defendant’s motion to dismiss plaintiff’s hostile work environment claim asserted under the New Jersey Law Against Discrimination (NJLAD). From the decision: Defendants move to dismiss Plaintiff’s NJLAD hostile work environment claim. “Claims…

Read More Hostile Work Environment Claim, Based on Display of Sexually Graphic Photograph, Survives Dismissal
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In Kennedy v. Ceva Logistics U.S., Ing., No. 3:23-cv-01362, 2025 WL 2231049 (M.D.Tenn. Aug. 5, 2025), the court, inter alia, denied defendants’ motion for summary judgment on plaintiff’s claim of race-based hostile work environment under Title VII of the Civil Rights Act of 1964. As to the element of “severity”, the court explained: CEVA attempts…

Read More Race-Based Hostile Work Environment Survives Summary Judgment; Evidence Included Alleged Use of N-Word & Slave-Related Comment
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In Fernandez v. American Sugar Refining, Inc., 2025 WL 2294879 (E.D.La. Aug. 8, 2025), the court, inter alia, discussed and applied the “administrative exhaustion” requirement applicable to claims asserted under Title VII of the Civil Rights Act of 1964. Initially, the court held that plaintiff did not administratively exhaust the sex-based discrimination claim: Defendant contends…

Read More Hostile Work Environment, But Not Sex Discrimination, Claim Survives Dismissal Based on “Administrative Exhaustion” at the EEOC
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In Shimeles v. Fairfax County School Board, Civil Action No. 1:24-cv-474 (RDA/IDD), 2025 WL 2375203 (E.D.Va. Aug. 14, 2025), the court, inter alia, held that plaintiff sufficiently alleged a racially-hostile work environment, in violation of Title VII of the Civil Rights Act of  1964. From the decision: Unwelcome conduct rises to the level of being…

Read More Race-Based Hostile Work Environment Sufficiently Alleged; Court Cites Claimed Threat of Hanging by Noose
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In Tardiff v. Laborers International Union of North American Local Union 609 et al, 2025 WL 2374000 (D.Mass. Aug. 15, 2025), the court, inter alia, held that plaintiff sufficiently alleged sexual harassment under Massachusetts state law and Title VII of the Civil Rights Act of 1964. From the decision: Ms. Tardiff has alleged that Mr.…

Read More Hostile Work Environment Sexual Harassment Claims Survive Dismissal; Allegations Include Disparaging Comments and Brandishing Firearm
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In Erazo v. IGH Restoration LLC, 23 Civ. 3982 (DEH), 2025 WL 2298712 (S.D.N.Y. Aug. 8, 2025), concerning alleged sexual harassment, the court denied defendants’ motion for summary judgment on plaintiff’s claims under Title VII of the Civil Rights Act of 1964. Specifically, this decision discusses the issue of whether a defendant is considered an…

Read More Sexual Harassment Plaintiff Presents Sufficient Evidence to Create Triable Issue as to Whether Defendant is a Title VII “Employer”
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In Lambert et al v. New Start Capital LLC et al, 1:24-cv-8055-GHW, 2025 WL 2295254 (S.D.N.Y. August 7, 2025), the court addressed a novel legal questions regarding the relatively new Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act (EFAA). In sum, one plaintiff – Lambert, a Black woman – alleges that she was…

Read More SDNY Interprets the EFAA to Apply to Sexual Harassment & Related Wage-and-Hour Claims, But Not to Third Plaintiff’s Claims Unrelated to Sexual Harassment Claims
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