Hostile Work Environment

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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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In Shimeles v. Fairfax County School Board, Civil Action No. 1:24-cv-474 (RDA/IDD), 2025 WL 2375203 (E.D.Va. Aug. 14, 2025), the court, inter alia, held that plaintiff sufficiently alleged a racially-hostile work environment, in violation of Title VII of the Civil Rights Act of  1964. From the decision: Unwelcome conduct rises to the level of being…

Read More Race-Based Hostile Work Environment Sufficiently Alleged; Court Cites Claimed Threat of Hanging by Noose
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In Tardiff v. Laborers International Union of North American Local Union 609 et al, 2025 WL 2374000 (D.Mass. Aug. 15, 2025), the court, inter alia, held that plaintiff sufficiently alleged sexual harassment under Massachusetts state law and Title VII of the Civil Rights Act of 1964. From the decision: Ms. Tardiff has alleged that Mr.…

Read More Hostile Work Environment Sexual Harassment Claims Survive Dismissal; Allegations Include Disparaging Comments and Brandishing Firearm
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In Erazo v. IGH Restoration LLC, 23 Civ. 3982 (DEH), 2025 WL 2298712 (S.D.N.Y. Aug. 8, 2025), concerning alleged sexual harassment, the court denied defendants’ motion for summary judgment on plaintiff’s claims under Title VII of the Civil Rights Act of 1964. Specifically, this decision discusses the issue of whether a defendant is considered an…

Read More Sexual Harassment Plaintiff Presents Sufficient Evidence to Create Triable Issue as to Whether Defendant is a Title VII “Employer”
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In Mofrad v. United Parcel Service, Inc., Case No. 23-cv-01899-AMO, 2025 WL 2308492 (N.D.Cal. Aug. 11, 2025), the court denied defendant’s motion for summary judgment on plaintiff’s claim of sexual harassment under California’s Fair Employment and Housing Act (“FEHA”). This decision is interesting, in that it arises from a scenario involving allegations by a male…

Read More Sexual Harassment Claim, Arising From Alleged Harassment of Male by Female Subordinate, Survives Summary Judgment
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In Choudhury v. Northwell Health, Inc., 23-cv-01406 (NCM) (SIL), 2025 WL 2300220 (E.D.N.Y. Aug. 8, 2025), the court, inter alia, denied defendants’ motion for summary judgment on plaintiff’s claims of race, religion, and national origin based hostile work environment asserted under the New York State Human Rights Law. Notably, the court initially granted defendants’ motion…

Read More Hostile Work Environment Claims Survive Summary Judgment Under NYS Human Rights Law (But Not Title VII)
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In Brunette v. Bausch Health US, LLC, Case # 22-CV-6376-FPG-CDH, 2025 WL 2240477 (W.D.N.Y. Aug. 2025), the court granted defendant’s motion for summary judgment dismissing plaintiff’s claims of age- and disability-based hostile work environment. This decision illustrates the well-established point, integral to employment law, that generally unpleasant conduct – such as being micromanaged, reprimanded, etc.…

Read More Age and Disability-Based Hostile Work Environment Claims Dismissed
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In Dassie v. Wilmer Cutler Pickering Hale and Dorr, LLP, No. 160227/2023, 2025 WL 2224323 (N.Y. Sup Ct, New York County Aug. 05, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s hostile work environment claims asserted under the New York City Human Rights Law. From the decision: A hostile work environment violates…

Read More Race, National Origin Discrimination-Based Hostile Work Environment Claims Dismissed Against WilmerHale
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In King v. Koch AG & Energy Solutions, LLC, CIVIL ACTION No. 25-1017-KHV, 2025 WL 2106828 (D.Kan. July 28, 2025), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s hostile work environment sexual harassment claim asserted under Title VII of the Civil Rights Act of 1964. Specifically, the court considered the effect on plaintiff’s…

Read More Sex-Based Hostile Work Environment Claim Sufficiently Alleged Under New “Muldrow” Standard
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