Hostile Work Environment

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In Lang v. District of Columbia, et al, 2023 WL 2708820 (D.D.C. March 30, 2023), the U.S. District Court for the District of Columbia dismissed plaintiff’s “failure to protect against hostile work environment” claim. From the decision: That leaves Plaintiff’s claims based on Defendants’ negligent failure to protect her from the hostile work environment. These…

Read More Court Declines to Recognize, and Dismisses, Hostile Work Environment Claim Based on “Negligent Supervision” Theory
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In Degefu v. Department of Veterans Affairs et al, Civil Action No. 20-cv-3548 (BAH), 2023 WL 2707494 (D.D.C. March 30, 2023), the court, inter alia, denied defendants’ motion for summary judgment on plaintiff’s hostile work environment claim. From the decision: The record before this Court suffices to meet the standard that a reasonable juror could…

Read More Hostile Work Environment Claim Survives Summary Judgment; Alleged Abusive Treatment Followed Accommodation Request
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In Sylla v. New York City Department of Education et al, 18-CV-6524 (RPK) (MMH), 2023 WL 2667072 (E.D.N.Y. March 28, 2023), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s race-based hostile work environment claim. In this case, plaintiff alleged that a co-worker repeatedly called him “mono”, which is Spanish for monkey.…

Read More “Monkey” Comments Cited in Decision Denying Summary Judgment on Race-Based Hostile Work Environment Claim
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In Judkins v. The Brooklyn Hospital Center et al, 2023 WL 2652279 (E.D.N.Y. March 27, 2023), the court, inter alia, granted defendants’ motion to dismiss plaintiff’s race- and sex-based hostile work environment claims asserted under Title VII of the Civil Rights Act of 1964 and 42 U.S.C. § 1981. To plead a claim for hostile work…

Read More Race, Sex-Based Hostile Work Environment Claims Dismissed; Favoring Friends Held Insufficient
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In Summerville v. Tradeweb Markets, LLC, No. 160245/2021, 2023 WL 2613131 (N.Y. Sup Ct, New York County Mar. 23, 2023), the court, inter alia, dismissed plaintiff’s race- and gender-based discrimination and hostile work environment claims asserted under the New York State and New York City Human Rights Laws. From the decision: Plaintiff alleges that the…

Read More Race/Gender Discrimination & Hostile Work Environment Claims Dismissed
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In White–Barnes v New York State Department of Corrections and Community Supervision, No. 535384, 2023 N.Y. Slip Op. 01561, 2023 WL 2602608 (N.Y.A.D. 3 Dept. Mar. 23, 2023), the court modifying and reversing a lower order dismissing, on summary judgment, plaintiff’s claim of an age-based hostile work environment leading to her constructive discharge. In sum,…

Read More “Grandma” Comments Result in Age-Based Discrimination, Hostile Work Environment, Constructive Discharge Claims Being Resurrected From Summary Judgment Dismissal
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In Atalla v. Rite Aid Corporation, 2023 WL 2521909 (Cal.App. 5 Dist. Feb. 24, 2023), the court granted defendant’s motion for summary judgment on plaintiff’s sexual harassment claim. The facts of this case include plaintiff’s supervisor sending her inappropriate text messages. Standing alone, these facts might initially suggest an actionable claim of sexual harassment. However,…

Read More Sexual Harassment Claims Dismissed; Inappropriate Text Messages Were Sent by Supervisor Not Acting in That Capacity
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In Johnson v. The City of Troy et al, 1:20-cv-1279 (MAD/TWD), 2023 WL 2587945 (N.D.N.Y. March 21, 2023), the court, inter alia, denied defendants’ motion for summary judgment on plaintiff’s race-based hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. After summarizing the “black letter” law governing this claim,…

Read More Title VII Race-Based Hostile Work Environment Claim Survives Summary Judgment Against City of Troy
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In a recent case, High v. Wells Fargo Bank, 2023 WL 2505540 (E.D.Va. March 14, 2023), the court offered interpretive guidance on 42 U.S.C. § 1981 which, generally, prohibits race discrimination in the making and enforcement of contracts (which has been interpreted to mean the “at will” employment relationship). While Title VII of the Civil…

Read More Court Discusses 42 U.S.C. § 1981’s Applicability Where National Origin Discrimination is Alleged
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In Schlegel v. Finney County, Kansas, Board of Commissioners, No. 21-1288-JAR-KGG, 2023 WL 2428900 (D.Kan. March 9, 2023), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s sexual orientation-based hostile work environment claim under Title VII of the Civil Rights Act of 1964. From the decision: Here, Plaintiff points to no single…

Read More Sexual Orientation-Based Hostile Work Environment Claim Survives Summary Judgment
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