Hostile Work Environment

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In Izuogu v. Credit Agricole Corporate and Investment Bank, New York, 24 Civ. 4329 (DEH), 2025 WL 2806683 (S.D.N.Y. Oct. 2, 2025), the court, inter alia, granted defendants’ motion to dismiss plaintiff’s hostile work environment claims under Title VII of the Civil Rights Act of 1964 and 42 U.S.C. 1981. From the decision: To establish…

Read More Hostile Work Environment Claims Dismissed; Remarks, Gossip, False Complaint Did Not Reference Race or National Origin
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In Lindsey v. Citigroup Global Markets Inc., 1:23-cv-10166-ALC, 2025 WL 2781281 (S.D.N.Y. Sept. 30, 2025), the court discussed and applied the “continuing violation” doctrine under Title VII of the Civil Rights Act of 1964. In sum, plaintiff alleges that she was subjected to a hostile work environment, commencing in 2007 with an alleged sexual assault,…

Read More Title VII Hostile Work Environment Claim Survives Motion to Dismiss; Applicability of “Continuing Violation” Doctrine Must Await Further Factual Development
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In Carey v. NYS Department of Health, 2025 WL 2732918 (S.D.N.Y. Sept. 25, 2025), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s sex-based hostile work environment claims asserted under the New York State and City Human Rights Laws. This decision illustrates the difference between the relatively restrictive federal law, on the…

Read More Sex-Based Hostile Work Environment Claims Survive Under New York State and City Human Rights Laws
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In Schneidermesser v. NYU Grossman School of Medicine, 2025 WL 2732877 (S.D.N.Y. Sept. 25, 2025), the court, inter alia, denied defendant’s motion for reconsideration of the court’s denial of its motion for summary judgment as to plaintiff’s age-based hostile work environment claim. From the decision: NYU Langone raises two arguments in its motion. First, it…

Read More Age-Based Hostile Work Environment Claim Survives Summary Judgment; Motion for Reconsideration Denied
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In Chislett v. New York City Department of Education, No. 24-972-cv, 2025 WL 2725669 (2d Cir. Sept. 25, 2025), the U.S. Court of Appeals for the Second Circuit, inter alia, vacated the lower court’s award of summary judgment on plaintiff’s race-based hostile work environment claim. As it was undisputed that plaintiff subjectively perceived the environment…

Read More Race-Based Hostile Work Environment Claim Survives Summary Judgment Against the NYC Department of Education
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In Brown v. Fat Dough Incorp. doing business as Dominos Pizza, 2025 WL 2663170 (N.D.N.Y. Sept. 17, 2025), the court, inter alia, granted defendant’s motion for summary judgment on plaintiff’s claim of sexual harassment asserted under Title VII of the Civil Rights Act of 1964. This decision illustrates that even “inappropriate behavior” may fall below…

Read More Title VII Sexual Harassment Claim, Based on “Inappropriate” Comments, Dismissed
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As a plaintiff-side employment lawyer in New York, I’ve heard it all. From whispers in the breakroom to explosive arguments in a manager’s office, the stories of “workplace drama” are as varied as the clients who share them. But here’s the truth: what many people dismiss as mere “drama” can actually be a sign of…

Read More Navigating the Storm: A Plaintiff-Side Employment Lawyer’s Guide to “Workplace Drama”
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In Pullman et al v. Collins et al, No. 24-CV-1383 (KMK), 2025 WL 2673807 (S.D.N.Y. Sept. 18, 2025), the court, inter alia, denied defendants’ motion to dismiss a plaintiff’s claim of hostile work environment sexual harassment asserted under the New York State Human Rights Law. From the decision: Next, Defendants argue that Dinsmore has failed…

Read More Sexual Harassment Claim Sufficiently Alleged Under Recently-Amended NYS Human Rights Law, Court Holds
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In Mimitz v. Safe Haven Security Services, LLC, 2025 WL 2650441 (Conn.Super. Sept. 9, 2025), the court granted defendant’s motion for summary judgment on plaintiff’s hostile work environment sexual harassment claim. From the decision: The defendant moves for summary judgment on the ground that there exists no genuine issue of material fact as to the…

Read More Hostile Work Environment Sexual Harassment Claim Dismissed; Alleged “Vulgar” Language Insufficient
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In Garcia v. Westhampton Primary Care, Maria Barlowe, Marie Alessi, and StaffCo of Brooklyn, LLC, 2025 WL 2614945 (E.D.N.Y. Sept. 10, 2025), the court, inter alia, held that plaintiff plausibly alleged a race-based hostile work environment claim ,as well as for a retaliatory hostile work environment, in violation of Title VII of the Civil rights…

Read More Race-Based Hostile Work Environment Claims Survive Dismissal
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