Hostile Work Environment

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In Quiles-Carrasquillo v. Louis DeJoy, Postmaster General of the U.S. Postal Service, Civil No. 23-1468 (FAB), 2025 WL 25672 (D.Puerto Rico Jan. 3, 2025), the court, inter alia, adopted a Magistrate Judge’s Report & Recommendation recommending the denial of defendant’s motion to dismiss plaintiff’s sex-based hostile work environment claim pursuant to Title VII of the…

Read More Hostile Work Environment Claim Sufficiently Alleged; Verbal Threats Were Sufficiently “Severe”
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In Smith v. Louis DeJoy, 2024 WL 5145956 (N.D.Ala. Dec. 17, 2024), the court, inter alia, granted defendant’s motion for summary judgment dismissing plaintiff’s hostile work environment claim. From the decision: Plaintiff’s termination was a single discrete event. So, in the absence of pervasiveness, the only way for her hostile work environment claim to survive…

Read More Hostile Work Environment Claim Dismissed; Termination Was Not Sufficiently “Severe”
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In James v. Denis McDonough in his official capacity as Secretary, United States Department of Veterans Affairs, Case No. 2:23-cv-02386-SHL-cgc, 2024 WL 5147647 (W.D.Tenn. Dec. 17, 2024), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s hostile work environment sexual harassment claim. From the decision: Here, James alleges that Strawder, who is…

Read More Title VII Hostile Work Environment Sexual Harassment Against VA Survives Summary Judgment
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In Ajala v. Limani 51, LLC, No. 153433/2023, 2024 WL 5169823 (N.Y. Sup Ct, New York County Dec. 17, 2024), the court held that plaintiff sufficiently alleged a hostile work environment claims under the New York State and City Human Rights Laws. From the decision: A racially hostile work environment exists when the workplace is…

Read More Hostile Work Environment Claim Survives Dismissal; Court Cites Sex and Race-Based Comments
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In Brooks v. Liberty Mutual Insurance Co., 2024 WL 5186527 (S.D.N.Y. Dec. 20, 2024), an employment discrimination/hostile work environment case, the court dismissed plaintiff’s third amended complaint (TAC). Interestingly, the court did not address the merits, but rather focused on the procedural requirements for such a complaint: Rule 8(a)(2) of the Federal Rules of Civil…

Read More 100+ Page Hostile Work Environment Complaint Dismissed as Being Neither “Short Nor Plain”
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In McConaughey v. Port Authority of New York and New Jersey, 21-CV-6137 (RA), 2024 WL 5168018 (S.D.N.Y. Dec. 18, 2024), the court denied defendant’s motion for summary judgment on plaintiff’s sex-based hostile work environment and retaliation claims asserted under Title VII of the Civil Rights Act of 1964. From the decision: McConaughey alleges that he…

Read More Title VII Sex-Based Hostile Work Environment, Retaliation Claims Survive Summary Judgment Against Port Authority
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In Troeger v. JetBlue Airways Corp., 2024 WL 5146185 (S.D.N.Y. December 17, 2024), the court denied defendant’s motion to dismiss plaintiff’s hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. After summarizing the black-letter law, the court applied it to the facts as follows: Here, Troeger does not allege…

Read More Hostile Work Environment Claim Survives Dismissal Against JetBlue, Court Holds
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In Sanchez v. New York City Housing Authority, 23-CV-8683 (JMF), 2024 WL 5119372 (S.D.N.Y. Dec. 16, 2024), the court, inter alia, granted summary judgment to defendant on plaintiff’s sex-based hostile work environment claims. From the decision: Next, Sanchez brings a hostile work environment claim under Title VII. To survive summary judgment on a hostile work…

Read More Sex-Based Hostile Work Environment Claims Dismissed; Employer’s Action Prevented Imputing Alleged Conduct
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In LaChapel v. Brio Solar Energy, LLC et al, 2024 WL 5089561 (N.D.Tex. Dec. 12, 2024), the court denied plaintiff’s motion for a default judgment on his hostile work environment asserted under Title VII of the Civil Rights Act of 1964. From the decision: LaChapel fails to state a cognizable claim for a hostile work…

Read More Hostile Work Environment Claim Fails, as Alleged Discriminatory Statements Were Not “Directed At” Plaintiff
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In Ancrum v. New York City Department of Environmental Protection, 2024 WL 5009145 (S.D.N.Y. Dec. 6, 2024), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s sexual harassment claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: For Title VII purposes, a workplace is actionably hostile when it…

Read More Title VII Sexual Harassment Claim Dismissed; Comments, While “Despicable” and “Offensive”, Held Not Actionable
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