Hostile Educational Environment

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In Oji v. Douglas A. Collins, Secretary, Department of Veterans Affairs, 2025 WL 2624975 (E.D.N.Y. Sept. 11, 2025), the court, inter alia, granted defendant’s motion for summary judgment on plaintiff’s race-based hostile work environment. From the decision: Though it is undisputed that Plaintiff subjectively viewed his working environment as a hostile one, Plaintiff has cited…

Read More Race-Based Hostile Work Environment Claim Dismissed; Alleged Comments by Non-Supervisor Held Insufficient
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A recent case, Bady v. Illinois Central Railroad Company, No. 2:21-cv-2693-MSN-cgc, 2023 WL 2482229 (W.D.Tenn. March 13, 2023), illustrates the difficulties encountered by plaintiffs in attempting to plead and prove a hostile work environment claim. To wit: Drawing a chalk line down Plaintiff’s buttock without his knowledge or consent, posting a photo about it, and…

Read More Hostile Work Environment Claim Insufficiently Alleged; “Chalk Buttock Line” Insufficient
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In a recent case, Boucher et al v. Trustees of Canisius College et al, No. 1:22-cv-00381, 2023 WL 2544625 (W.D.N.Y. March 17, 2023), the court denied defendant’s motion to dismiss plaintiff’s “hostile educational environment” sexual harassment claim asserted under Title IX of the Educational Amendments of 1972, 20 U.S.C. § 1681. Plaintiffs allege, in sum,…

Read More Sexual Harassment/Hostile Educational Environment Claim Survives Dismissal Against Trustees of Canisius College
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