In Sean C.I.R. v. Nexstar Media Group Inc., No. 150543/2024, 2025 WL 944582, 2025 N.Y. Slip Op. 30975(U), 7–8 (N.Y. Sup Ct, New York County Mar. 28, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s claims of a race-based hostile work environment under the New York State and City Human Rights Laws.…
Read More Race-Based Hostile Work Environment Claims DismissedIn Smith v. National Grid USA, 2:21-cv-6899 (NJC) (LGD), 2025 WL 1248676 (E.D.N.Y. April 30, 2025), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s race-based hostile work environment claims. From the decision: [T]here are numerous genuine disputes of material fact concerning Smith’s hostile work environment claims—under both the higher federal standard…
Read More Race-Based Hostile Work Environment Claims Survive Summary Judgment; Allegations Include “Shine Box” and “Monkey” CommentsIn McCardle v. District of Columbia, Case No. 19-cv-3637 (JMC), 2025 WL 1167956 (D.D.C., 2025), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s claim of age-based hostile work environment asserted under the Age Discrimination in Employment Act (ADEA). From the decision: The District argues that McArdle cannot establish a hostile work…
Read More Age-Based Hostile Work Environment Claim Survives Summary JudgmentIn Smart, Kathyann v. USA Labor for Hire, Inc., RC Global Energy Group, Inc., Oleg Tsimbler, No. 24-1791, 2025 WL 1217365 (2d Cir. April 28, 2025), the U.S. Court of Appeals for the Second Circuit, inter alia, affirmed the lower court’s denial of defendant’s motion for new trial or remittitur on plaintiff’s claims of hostile…
Read More 2nd Circuit Holds That Jury Properly Found Hostile Work Environment, Based on Racially Derogatory and Sexist Language,In Yuliano v. Cent. Park West Orthodontics P.C., No. 161370/2019, 2025 WL 1168160 (N.Y. Sup Ct, New York County Apr. 22, 2025), the court denied defendants’ motion for summary judgment on plaintiff’s hostile work environment claim asserted under the New York City Human Rights Law. From the decision: The City HRL must be “construed liberally…
Read More Citing Alleged Instruction to “Sexualize” Plaintiff’s Appearance, Court Allows Hostile Work Environment Claim to ProceedIn Noh v. Admarketplace, Inc., 24 Civ. 2107 (ER), 2025 WL 965882 (S.D.N.Y. March 28, 2025), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s sex- and race-based hostile work environment claims asserted under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 1981, and the New York State and City…
Read More Hostile Work Environment Claim, Based on Race and Sex, Survive DismissalIn Huber v. TIAA, 2025 WL 1139131 (W.D.Va. April 17, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s hostile work environment claim in violation of Title VII of the Civil Rights Act of 1964. In sum, plaintiff alleged that defendant engaged in religious discrimination by failing to accommodate her request for a…
Read More Title VII Religion-Based Hostile Work Environment Claim DismissedIn Fisher v. N-Stock Box, Inc., Case No. 1:23-cv-15, 2025 WL 1141842 (S.D.Ohio April 16, 2025), an employment discrimination case, the court granted defendant’s motion for judgment on the pleadings as to plaintiff’s hostile work environment claims, on the ground that plaintiff did not exhaust his administrative remedies at the U.S. Equal Employment Opportunity Commission…
Read More Hostile Work Environment Claims Dismissed Due to Failure to Exhaust Administrative RemediesIn Rosenson v. Bloomfield, Civil Action No. 24-1365 (SLS), 2025 WL 958254 (D.D.C. March 31, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s retaliatory hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: To prevail on a retaliatory hostile-work-environment claim, “a plaintiff must…
Read More Hostile Work Environment Claim Dismissed; Repeated Criticism and Other Actions Held Insufficiently Severe or PervasiveIn Gildyard v. Children’s Network of Southwest Florida, LLC, Case No.: 2:24-cv-702-SPC-KCD, 2025 WL 1093331 (M.D.Fla. April 10, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s race-based hostile work environment claim, on the ground that plaintiff failed to “administratively exhaust” that claim at the U.S. Equal Employment Opportunity Commission. From the decision:…
Read More Race-Based Hostile Work Environment Claim Dismissed on “Administrative Exhaustion” Grounds