Hostile Work Environment

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In Williams v. Family Health International d/b/a FHI 360 et al, 2025 WL 2506580 (D.D.C. Sept. 2, 2025), the court, inter alia, held that plaintiff did not state a claim for hostile work environment under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 1981, and the District of Columbia Human Rights…

Read More Hostile Work Environment Claims Dismissed; Alleged Actions Were “Ordinary, Albeit Unpleasant”, Workplace Conduct
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In Garcia v. Westhampton Primary Care, 2:23-cv-4319 (NJC) (ST), 2025 WL 2494357 (E.D.N.Y. Aug. 30, 2025), the court, inter alia, held that plaintiff plausibly alleged claims of hostile work environment under Title VII of the Civil Rights Act of 1964 and the New York State Human Rights Law. The court summarized, and applied, the law…

Read More Hostile Work Environment, Retaliatory Hostile Work Environment Claims Survive Dismissal
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In Hechavarria v. Scorch Bar & Grill Inc., 23-CV-1743 (NGG) (VMS), 2025 WL 2476346 (E.D.N.Y. Aug. 28, 2025), the U.S. District Court for the Eastern District of New York, inter alia, denied defendants’ motion for summary judgment on plaintiff’s race-based hostile work environment claims. Plaintiff contends, among other things, that he was engaged in an…

Read More One-Time N-Word Use Sufficient to Defeat Summary Judgment on Race-Based Hostile Work Environment Claims, EDNY Holds
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In Rachwalski v. Pamela Bondi et al, 2025 WL 2432162 (S.D.Ind. Aug. 21, 2025), the court, inter alia, granted defendants’ motion for summary judgment on plaintiff’s sex-based hostile work environment claim asserted under Title VII of the Civil Right Act of 1964. From the decision: Title VII prohibits employers from discriminating against employees based on…

Read More Sex-Based Hostile Work Environment Claim Dismissed; Alleged Conduct Was Not Objectively Offensive Nor Severe or Pervasive
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In Nash v. City of Cincinnati et al, 2025 WL 2403821 (S.D.Ohio Aug. 19, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s race-based hostile work environment claim. From the decision: Defendants next move to dismiss Plaintiff’s hostile work environment claim. (Motion, Doc. 4, Pg. ID 42.) Title VII protects an employee who…

Read More Race-Based Hostile Work Environment Claim Dismissed; Alleged Events, While “Troubling,” Were Too Remote
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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 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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