Hostile Work Environment

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In Erno v. New York State Office of Information Technology Services, No. 1:19-CV-1457, 2022 WL 1224325 (N.D.N.Y. April 26, 2022), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s hostile work environment sexual harassment claim under Title VII of the Civil Rights Act of 1964 (but not under the New York State Human…

Read More Hostile Work Environment Sexual Harassment Claim, Against NYS Office of Information Technology Services, Survives Summary Judgment
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In Dunham v. Hartford Board of Education, No. HHD-CV-206129681-S, 2022 WL 1223917 (Conn. Super. April 26, 2022), the court, inter alia denied defendant’s motion for summary judgment on plaintiff’s hostile work environment sexual harassment claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: A hostile work environment claim requires…

Read More Sexual Harassment (Hostile Work Environment) Claim Survives Summary Judgment Against Hartford Board of Education
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In Armijo v. Costco Wholesale Warehouse, Inc., No. 19-00484-ACK-RT, 2022 WL 1267254 (D.Hawai’i April 28, 2022), the court, inter alia, granted defendant’s motion for summary judgment on plaintiff’s disability-based hostile work environment claim. The court summarized the pertinent law as follows: A hostile work environment claim relies on a series of separate acts that collectively…

Read More Disability-Based Hostile Work Environment Claim Dismissed Against Costco
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In Moore v. Louis Dejoy, 18-CV-9967, 2022 WL 1239688 (S.D.N.Y. April 27, 2022), the court dismissed plaintiff’s age-based hostile work environment claim, since plaintiff did not “administratively exhaust” that claim at the U.S. Equal Employment Opportunity Commission. From the decision: Because she did not file a formal complaint regarding alleged improper comments or a hostile…

Read More Hostile Work Environment Claim Not Administratively Exhausted; Dismissed
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In Durand v. Shull, 2022 WL 1184041 (10th Cir. April 21, 2022), the Tenth Circuit affirmed the lower court’s application of qualified immunity to grant defendant’s motion for summary judgment on plaintiff’s race-based hostile work environment claim. In sum, plaintiff – a Black female who worked as a Youth Services Specialist at a juvenile detention…

Read More Tenth Circuit Affirms Dismissal of Race-Based Hostile Work Environment Claim; Cites Relevance of Prison Context
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In Bouziotis v. Iron Bar, LLC, 2022 WL 1144916 (N.J. Super. A.D. April 19, 2022), the court affirmed the dismissal of plaintiff’s gender-based hostile work environment under the New Jersey Law Against Discrimination (LAD). In sum, plaintiff alleged that, among other things, instead of using plaintiff’s proper name, the defendant bar’s part owner (individual defendant…

Read More Hostile Work Environment Claim Dismissed; “Loutish”, “Unprofessional”, “Inappropriate” Conduct Insufficient
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In Chica v. Shallu Construction Corp., 21-cv-869, 2022 WL 970744 (E.D.N.Y. March 31, 2022), the court, inter alia, held that plaintiffs – who are Hispanic and of Latin American descent – sufficiently alleged race-based hostile work environment claims against defendants. As to individual defendant Amninder Singh, the court explained: Plaintiffs have pleaded a “steady barrage…

Read More Race (Hispanic)-Based Hostile Work Environment Claims Sufficiently Alleged
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In Miller v. New York State Police et al, 2022 WL 1133010 (2d Cir. April 18, 2022), the U.S. Court of Appeals for the Second Circuit, inter alia, affirmed the lower court’s dismissal (on summary judgment) of plaintiff’s race-based hostile work environment claim. After summarizing the well-established black-letter law of hostile work environment claims, the…

Read More Race-Based Hostile Work Environment Claim Properly Dismissed; Alleged 12 Incidents Over 3 Years Insufficient
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In Davis v. Elwyn, Inc., 20-cv-05798, 2022 WL 970842 (E.D.Pa. March 31, 2022), the court, inter alia, dismissed plaintiff’s hostile work environment claims asserted under Title VII of the Civil Rights Act of 1964. Plaintiff, who worked as a Mental Health Program Specialist for defendant, alleged that defendant subjected her to a hostile work environment…

Read More Sex/Race-Based Hostile Work Environment Claims Dismissed; Mental Health Specialist Did Not Suffer “Objectively” Hostile Environment Resulting From Patient’s Alleged Harassment
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In Taylor v. Haaland, 2022 WL 990682 (D.D.C. March 31, 2022), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s hostile work environment claim. After summarizing the “black letter” law governing such a claim, the court applied it to the facts: Here, Taylor argues that the Department created a hostile work environment by: (1)…

Read More Hostile Work Environment Claim Dismissed; “Unpleasant” and “Offensive” Conduct Insufficient
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