Hostile Work Environment

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In Cadet v. Macy’s, Inc., No. 22-CV-7406 (VSB), 2026 WL 1998595 (S.D.N.Y. July 10, 2026), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s claims of race and national origin-based hostile work environment. As to the issue of whether the alleged conduct was sufficiently “severe” or “pervasive” under 42 USC § 1981…

Read More Race, National Origin Based Hostile Work Environment Claims Against Macy’s Survive Summary Judgment
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In Alcodray v. Michigan Department of Corrections & Sherman Campbell, No. 25-12122, 2026 WL 1984108 (E.D. Mich. July 9, 2026), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964, on the ground that plaintiff failed to exhaust his administrative…

Read More Title VII Hostile Work Environment Claim Dismissed; Plaintiff Failed to Exhaust Administrative Remedies at the EEOC
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In Miller v. Markwayne Mullin et al, No. 1:25-CV-00703-JRR, 2026 WL 1861955 (D. Md. June 29, 2026), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s race-based hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: Here, Defendant argues all the alleged discrete discriminatory incidents…

Read More Race-Based Hostile Work Environment Claim Dismissed; Evidence, Including Monkey Emoji, Insufficient
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In Prager v. Lab’y Corp. of Am. Holdings, No. CV2323413 (MAS)(JBD), 2026 WL 1879303 (D.N.J. June 30, 2026), the court held that plaintiff failed to make out a hostile work environment claim in violation of Title VII of the Civil Rights Act of 1964. From the decision: To succeed on a hostile work environment claim…

Read More Title VII Hostile Work Environment Claim Dismissed; Alleged Conduct Did Not Meet “Severe or Pervasive” Threshold
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In Hobson v. Green Finance Authority et al, No. CV 26-531 (JDB), 2026 WL 1878465 (D.D.C. June 30, 2026), the court, inter alia, held that plaintiff failed to sufficiently allege a hostile work environment claim in violation of the D.C. Human Rights Act (which, the court explained, is evaluated under the same standard as under…

Read More Hostile Work Environment Claim Dismissed; Alleged Conduct Was Not Tied to Protected Status, or “Severe” or “Pervasive”
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In Dobbins v. Rollins, No. 25-1465, 2026 WL 1813421 (8th Cir. June 24, 2026), the U.S. Court of Appeals for the Eighth Circuit affirmed the lower court’s award of summary judgment on plaintiff’s disability discrimination claim under the Rehabilitation Act. From the decision: Dobbins says her depression, anxiety, and PTSD disabled her and that she…

Read More Disability Discrimination Claim Properly Dismissed; Evidence Insufficient to Connect Objectionable Conduct to Plaintiff’s Disability, Rather Than Frustration With Tardiness and Absences
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In Haghnegahdar v. Old Dominion University, No. 2:25-CV-799, 2026 WL 1878607 (E.D. Va. June 30, 2026), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s claim of sex0based hostile work environment under Title VII of the Civil Rights Act of 1964. From the decision: The plaintiff alleges that ODU’s conduct—hiring her via a formal…

Read More Sex-Based Hostile Work Environment Claim Dismissed; Conduct Did Not Interfere With Plaintiff’s Ability to Do Her Job
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In Small v. Metropolitan Transit Authority (MTA), No. 158315/2024, 2026 WL 1880199 (N.Y. Sup. Ct. June 23, 2026), the court, inter alia, held that plaintiff’s discrimination and hostile work environment claims are barred by the “election of remedies” doctrine under the New York State Human Rights Law. From the decision: [The NYSHRL] provides that “any…

Read More Discrimination, Hostile Work Environment Claims Barred by Election-of-Remedies Doctrine
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In Amble v. City of Rockford Fire Dep’t., No. 3:22-CV-50196, 2026 WL 1846509 (N.D. Ill. June 26, 2026), the court, inter alia, granted defendant’s motion for summary judgment as to plaintiff’s constructive discharge claim. Among other things, plaintiff alleged that she was subjected to a conversation about oral sex, found pornography in the restroom, and…

Read More Constructive Discharge Claim Dismissed; While Work Environment May Have Been “Unhealthy,” It Was Not Sufficiently “Intolerable”
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In Carmichael, Shayla v. Commonwealth of Pennsylvania, Department of Human Services, No. CV 24-6307, 2026 WL 1846548 (E.D. Pa. June 26, 2026), the court, inter alia, granted defendant’s motion for summary judgment on plaintiff’s sex-based hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. The facts, in sum: Plaintiff’s…

Read More Sex-Based Hostile Work Environment Claim Dismissed; “Crass” Comments About Plaintiff’s Body, Appearance, and Clothing Not “Severe or Pervasive”
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