Hostile Work Environment

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In Zimpfer v. Hilbert College, Case No. 1:21-cv-231, 2025 WL 1758266 (W.D.N.Y. June 25, 2025), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s hostile work environment claim asserted under the (amended) New York State Human Rights Law. From the decision: As to the NYSHRL hostile-work-environment claim, Defendants cite authority indicating that…

Read More Hostile Work Environment Claim Sufficient to Withstand Summary Judgment Under Newly-Amended NYS Human Rights Law
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In Collins, Sam v. Federal Express Corporation, 2025 WL 1764809 (2d Cir. June 26, 2025), the U.S. Court of Appeals for the Second Circuit, inter alia, affirmed the lower court’s dismissal of plaintiff’s hostile work environment claims as being time-barred. From the decision: We also agree that Collins’ hostile-work-environment claims are time-barred. A hostile work…

Read More Hostile Work Environment Claims Against FedEx Properly Dismissed as Time-Barred, 2nd Circuit Holds
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In Simmons v. Baccarat Inc., No. 651516/2023, 2025 WL 1735659 (N.Y. Sup Ct, New York County June 23, 2025), the court, inter alia, granted plaintiff’s motion to dismiss plaintiff’s claims of hostile work environment and sexual harassment under the New York State and City Human Rights Laws. From the decision: The Moving Defendants correctly assert…

Read More Hostile Work Environment, Sexual Harassment Claims Dismissed; Evidence Indicated That Plaintiff Participated in “Sexually Themed” Text Messages
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In Kapllanaj v. Healthfirst PHSP, Inc., No. 152720/2021, 2025 WL 1707852 (N.Y. Sup Ct, New York County June 17, 2025), the court, inter alia, denied defendants’ motion for summary judgment on plaintiff’s gender discrimination and hostile work environment claims asserted under the New York State and City Human Rights Laws. The court summarized the facts…

Read More Sexual Harassment Claims Against Healthfirst Survive Summary Judgment
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In Samuel v. Institute for Community Living, Inc., No. 150885/2024, 2025 WL 1180332 (N.Y. Sup Ct, New York County Apr. 22, 2025), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s employment discrimination, hostile work environment, and retaliation claims. The court summarized the facts as follows: Plaintiff alleges she always performed her work satisfactorily…

Read More Age Discrimination, Hostile Work Environment, Retaliation Claims Survive Dismissal; Allegations Include “Old Bitch”, “Fat Loser”, and “Piece of Crap” Comments
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In Baxter v. Swiftshift Inc., 24cv6241 (DLC), 2025 WL 1677712 (S.D.N.Y. June 13, 2025), the court, inter alia, held that plaintiff sufficiently alleged claims of hostile work environment, under the New York State and City Human Rights Laws, because of her sex and domestic violence victim status. From the decision: Baxter has also stated a…

Read More Hostile Work Environment Claims, Based on Sex and Domestic Violence Victim Status, Survive Dismissal
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In Ruiz v. Credit Agricole Corporate and Investment Bank, Anthony Botting, 2025 WL 1642406 (S.D.N.Y. June 10, 2025), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s race-based hostile work environment claim asserted under the New York City Human Rights Law. From the decision: I turn next to Plaintiff’s claim under the NYCHRL that…

Read More Race-Based Hostile Work Environment Claim, Asserted Under the NYC Human Rights Law, Survives Dismissal
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In Cosenza v. Rivian Automotive, LLC, Case No. 1:23-cv-01297-JEH, 2025 WL 1603911 (C.D.Ill. April 24, 2025), the court, inter alia, held that plaintiff’s allegations met the “severe or pervasive” standard in connection with her claim of hostile work environment sexual harassment claim asserted under Title VII of the Civil Rights Act of 1964. After reviewing…

Read More Hostile Work Environment Sexual Harassment Claim Survives Summary Judgment; Allegations Include “Nice Tits” and Other Comments
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In Regis v. Noem, Civil Action No. 24-2405 (SLS), 2025 WL 1580808 (D.D.C. June 4, 2025), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s complaint alleging age discrimination under the Age Discrimination in Employment Act (ADEA). Plaintiff, a 59 year-old former fingerprint specialist at the United States Secret Service, alleged that defendant subjected…

Read More Secret Service Fingerprint Specialist’s Age Discrimination Claim Survives Dismissal
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In Russo v. Tuttnauer USA Company Limited et al, 21-cv-1720 (JMA)(AYS), 2025 WL 1604063 (E.D.N.Y. June 6, 2025), the court granted defendants’ motion for remittitur as to the jury’s award of $2.5 million for compensatory damages on plaintiff’s hostile work environment claim. The court explained, and applied, the law as follows: Under applicable New York…

Read More Hostile Work Environment Emotional Damages Award of $2.5 Million Remitted to $1 Million
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