Hostile Work Environment

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In Woo v. The City of New York, No. 161109/2022, 2025 WL 65869 (N.Y. Sup Ct, New York County Jan. 8, 2025), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s quid pro quo and hostile work environment sexual harassment claims. From the decision: The issue in a quid pro quo sexual harassment case brought…

Read More Sexual Harassment Claims Survive Dismissal; Allegations Included That Punitive Assignments Followed Drink Request Refusal
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In Dixon v. City of New York, 23-cv-8941 (JGK), 2025 WL 50140 (S.D.N.Y. Jan. 7, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s disability-based hostile work environment claims. This decision illustrates that generalized objectionable conduct – such as what might be considered “verbal harassment” – is alone insufficient to constitute an actionable…

Read More Disability-Based Hostile Work Environment Claims Dismissed; Allegation of Being Addressed in a “Loud, Aggressive and Belligerent Tone” Insufficient
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In Equal Employment Opportunity Commission v. Fred Meyer Stores, Inc., NO. 4:24-CV-5085-TOR, 2024 WL 5077603 (E.D.Wash., 2024), the court denied defendant’s motion to dismiss or for a more definite statement (pursuant to Federal Rule of Civil Procedure 12(e)). From the decision: In the present matter, the Complaint satisfies the requirement of a hostile work environment…

Read More Hostile Work Environment Sexual Harassment Claim Sufficiently Alleged; Motion to Dismiss or For More Definite Statement Denied
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In Zuber v. Republic First Bancorp Inc., No. 23-991, 2024 WL 5147018 (E.D.Pa. Dec. 17, 2024), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. As to whether the alleged harassment was sufficiently “severe or pervasive”, the…

Read More Hostile Work Environment Sexual Harassment Claim Survives Summary Judgment; Court Cited Alleged Request to Have Sex at Work Despite Prior Rejection
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In Quiles-Carrasquillo v. Louis DeJoy, Postmaster General of the U.S. Postal Service, Civil No. 23-1468 (FAB), 2025 WL 25672 (D.Puerto Rico Jan. 3, 2025), the court, inter alia, adopted a Magistrate Judge’s Report & Recommendation recommending the denial of defendant’s motion to dismiss plaintiff’s sex-based hostile work environment claim pursuant to Title VII of the…

Read More Hostile Work Environment Claim Sufficiently Alleged; Verbal Threats Were Sufficiently “Severe”
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In Smith v. Louis DeJoy, 2024 WL 5145956 (N.D.Ala. Dec. 17, 2024), the court, inter alia, granted defendant’s motion for summary judgment dismissing plaintiff’s hostile work environment claim. From the decision: Plaintiff’s termination was a single discrete event. So, in the absence of pervasiveness, the only way for her hostile work environment claim to survive…

Read More Hostile Work Environment Claim Dismissed; Termination Was Not Sufficiently “Severe”
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In James v. Denis McDonough in his official capacity as Secretary, United States Department of Veterans Affairs, Case No. 2:23-cv-02386-SHL-cgc, 2024 WL 5147647 (W.D.Tenn. Dec. 17, 2024), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s hostile work environment sexual harassment claim. From the decision: Here, James alleges that Strawder, who is…

Read More Title VII Hostile Work Environment Sexual Harassment Against VA Survives Summary Judgment
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In Ajala v. Limani 51, LLC, No. 153433/2023, 2024 WL 5169823 (N.Y. Sup Ct, New York County Dec. 17, 2024), the court held that plaintiff sufficiently alleged a hostile work environment claims under the New York State and City Human Rights Laws. From the decision: A racially hostile work environment exists when the workplace is…

Read More Hostile Work Environment Claim Survives Dismissal; Court Cites Sex and Race-Based Comments
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In Brooks v. Liberty Mutual Insurance Co., 2024 WL 5186527 (S.D.N.Y. Dec. 20, 2024), an employment discrimination/hostile work environment case, the court dismissed plaintiff’s third amended complaint (TAC). Interestingly, the court did not address the merits, but rather focused on the procedural requirements for such a complaint: Rule 8(a)(2) of the Federal Rules of Civil…

Read More 100+ Page Hostile Work Environment Complaint Dismissed as Being Neither “Short Nor Plain”
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In McConaughey v. Port Authority of New York and New Jersey, 21-CV-6137 (RA), 2024 WL 5168018 (S.D.N.Y. Dec. 18, 2024), the court denied defendant’s motion for summary judgment on plaintiff’s sex-based hostile work environment and retaliation claims asserted under Title VII of the Civil Rights Act of 1964. From the decision: McConaughey alleges that he…

Read More Title VII Sex-Based Hostile Work Environment, Retaliation Claims Survive Summary Judgment Against Port Authority
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