Hostile Work Environment

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In Sfanos v. Cranberry Crossroads Dining Venture, LLC, 2:23-CV-1502, 2024 WL 4827171 (W.D.Pa. Nov. 19, 2024), the court, inter alia, held that plaintiff sufficiently alleged a sex-based hostile work environment claim under Title VII of the Civil Rights Act of 1964. From the decision: Most of Ms. Sfanos’s sex-related allegations amount to inappropriate comments of…

Read More Sex-Based Hostile Work Environment Claim Survives Dismissal; Allegations Include Sexual Comments and a “Humping Gesture”
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In Ibhawa v New York State Division of Human Rights, No. 100, 2024 N.Y. Slip Op. 05872, 2024 WL 4884944 (N.Y., Nov. 26, 2024), the New York Court of Appeals held that the the First Amendment’s “ministerial exception” did not deprive the New York State Division of Human Rights (DHR) of jurisdiction over the employee’s…

Read More Hostile Work Environment Claim’s Dismissal Per “Ministerial Exception” Was Erroneous, NY Court of Appeals Holds
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In Mazzuchelli v. Immutable Pty. Ltd and Lightsource Global, 23-cv-7885 (NSR), 2024 WL 4817535 (S.D.N.Y. Nov. 18, 2024), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s hostile work environment sexual harassment claim asserted under Title VII of the Civil Rights Act of 1964. The court summarized and applied the law as follows: A…

Read More Title VII Hostile Work Environment Claim Dismissed; Alleged “Graphic Sexual Discussions” and “Sexual Overtures” Notwithstanding
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In Santay v. Ice House LLC, Civil Action No. 24-cv-11583-ADB, 2024 WL 4804967 (D.Mass. Nov. 15, 2024), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s national origin-based hostile work environment claim. After summarizing the black-letter law, and concluding that plaintiff sufficiently alleged a hostile work environment sexual harassment claim, the court applied the law to…

Read More National Origin-Based Hostile Work Environment Claim Sufficiently Alleged; Contentions Included Threats to “Call Immigration”
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In Santay v. Ice House LLC, Civil Action No. 24-cv-11583-ADB, 2024 WL 4804967 (D.Mass. Nov. 15, 2024), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s hostile work environment sexual harassment claim. From the decision: The elements of a claim for hostile work environment under Title VII or Chapter 151B are that (1) the…

Read More Hostile Work Environment Sexual Harassment Claim Sufficiently Alleged; Contentions Include Sexual Comments, Touching, and Showing Photos and Videos of Genitalia
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In Bolton v. General Motors, 2024 WL 4707965 (N.D.Ind. Nov. 6, 2024), the court, inter alia, dismissed plaintiff’s Title VII hostile work environment claim, on the ground that plaintiff did not “administratively exhaust” that claim at the Equal Employment Opportunity Commission (EEOC). From the decision: Bolton checked the box for discrimination based on race and…

Read More Hostile Work Environment Claim Dismissed on Administrative Exhaustion Grounds
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In Conlan v. Liberty Mutual Group, Inc. and Charles Bruce Stark, 2024 WL 4792112 (S.D.N.Y. Nov. 13, 2024), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s sex-based hostile work environment claim asserted under the New York State Human Rights Law. The court summarized the facts, in part, as follows: Shortly after Plaintiff began…

Read More Hostile Work Environment Sexual Harassment Claim Sufficiently Alleged Against Liberty Mutual, Court Holds
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In Jean-Pierre v. City of New York, No. 153859/2023, 2024 WL 4753498 (N.Y. Sup Ct, New York County Nov. 12, 2024), the court denied defendant’s motion to dismiss plaintiff’s claims of race discrimination and hostile work environment. From the decision: Plaintiff’s amended complaint alleges sufficient facts to support claims of discrimination and hostile work environment…

Read More Race-Based Discrimination & Hostile Work Environment Claims Sufficiently Alleged Against City of New York, Court Holds
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In Robinson v. District of Columbia, 2024 WL 4722157 (D.D.C. Nov. 8, 2024), the court, inter alia, dismissed plaintiff’s claim of race-based hostile work environment asserted under Title VII of the Civil Rights Act of 1964. After explaining that plaintiff failed to plead a timely hostile work environment claim, the court continued: Plaintiff’s hostile work…

Read More Title VII Race-Based Hostile Work Environment Claim Dismissed Against the District of Columbia
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In Hatcher v. New York City Department of Education, 23-cv-3510 (NRM) (LB), 2024 WL 4333643 (E.D.N.Y. Sept. 27, 2024), the court, inter alia, held that plaintiff sufficiently alleged a race-based hostile work environment claims under Title VII of the Civil Rights Act of 1964, the New York State Human Rights Law, and the New York…

Read More Speech Therapy Teacher Sufficiently Alleges Race-Based Hostile Work Environment, Court Holds
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