Hostile Work Environment

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In Ellis v. City of New York, No. 159090/2022, 2024 WL 1195688 (N.Y. Sup Ct, New York County Mar. 20, 2024), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s hostile work environment claims asserted under the New York State and City Human Rights Laws. From the decision: In this instance, Plaintiff further asserts…

Read More Hostile Work Environment Claims, Including Allegations of “Slave-Esque Working Conditions”, Dismissed
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In Harlow v. Molina Healthcare, Inc., 5:20-CV-1382, 2024 WL 1126736 (N.D.N.Y. March 15, 2024), the court, inter alia, denied defendant’s motion for summary judgment on her hostile work environment sexual harassment claims asserted under Title VII of the Civil Rights Act of 1964 and the New York State Human Rights Law. After summarizing the black-letter law, the…

Read More Hostile Work Environment (Same-Sex) Sexual Harassment Claims Survive Summary Judgment; Evidence Included Unwanted Touching and Suggestive Language
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In Renondeau v. Wildlife Conservation Society, New York Aquarium et al, 19-CV-2415 (VSB), 2024 WL 1156643 (S.D.N.Y. March 18, 2024), the court, inter alia, granted defendants’ motion for summary judgment dismissing plaintiff’s hostile work environment claim. From the decision: Plaintiff’s hostile work environment claim is based on many of the same allegations that underlie his…

Read More Hostile Work Environment Claim Dismissed; “Haitian Motherfucker” & “Haitian Sensation” Comments Insufficient
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In Nofal v. IMCMV Times Square LLC et al, 22 Civ. 3104 (DEH), 2024 WL 1138928 (S.D.N.Y. March 15, 2024), the court, inter alia, granted defendant’s motion for summary judgment on plaintiff’s religion-based hostile work environment claim. Plaintiff, who is Muslim, predicated his religious-discrimination claim on a single comment, namely, telling plaintiff that if he…

Read More Religion-Based Hostile Work Environment Claim Dismissed; Single Comment Insufficient
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In Shkoza v. NYC Health & Hospitals Corporation, No. 20-CV-3646 (RA), 2024 WL 1116145 (S.D.N.Y. March 13, 2024), the court, inter alia, granted defendant’s motion for summary judgment on plaintiff’s hostile work environment sexual harassment claim asserted under the New York City Human Rights Law. From the decision: [Plaintiff] Shkoza also brings an underlying claim…

Read More Sexual Harassment Claim Dismissed; Shoulder Touching Insufficient, Court Holds
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In Floyd v. Jewish Bd. of Family and Children’s Services, No. 155925/2019, 2024 WL 1096320 (N.Y. Sup Ct, New York County Mar. 13, 2024), the court, inter alia, granted defendant’s motion for summary judgment dismissing plaintiff’s claim of hostile work environment based on plaintiff’s sexual orientation, in violation of the New York City Human Rights…

Read More Sexual Orientation-Based Hostile Work Environment Claim Dismissed
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In Kagel-Betts v Warren, No. 601810/2023, 81 Misc. 3d 1233(A), 202 N.Y.S.3d 723, 2024 N.Y. Slip Op. 50055(U), 2024 WL 237743 (N.Y. Sup. Ct. Suffolk Cty. Jan. 12, 2024), the court, inter alia, dismissed plaintiff’s hostile work environment claim asserted under the New York State Human Rights Law. As to that claim, the court explained:…

Read More Court Dismisses Hostile Work Environment Claim, Citing Lack of Examples of Alleged Conduct
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In Phillips v. Fashion Institute of Technology et al, No. 23-375-cv, 2024 WL 1005500 (2d Cir. March 8, 2024), the U.S. Court of Appeals for the Second Circuit, inter alia, vacated a lower court’s summary judgment on her retaliatory hostile work environment claims against an individual defendant who, according to plaintiff, threatened to “kill” her.…

Read More 2nd Circuit Vacates Dismissal of Black FIT Employee’s Retaliatory Hostile Work Environment Claims
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In Moore, Kim v. Hadestown Broadway Limited Liability Company, No. 23-CV-4837 (LAP), 2024 WL 989843 (S.D.N.Y. March 7, 2024), the U.S. District Court for the Southern District of New York (in an opinion authored by Judge Preska), inter alia, denied defendant’s motion to dismiss plaintiff’s race-based hostile work environment claims. (I wrote about the court’s…

Read More Actress Plausibly Alleges Race-Based Hostile Work Environment Claims Under NYS and NYC Human Rights Laws (But Not Title VII)
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In Moore, Kim v. Hadestown Broadway Limited Liability Company, No. 23-CV-4837 (LAP), 2024 WL 989843 (S.D.N.Y. March 7, 2024), the U.S. District Court for the Southern District of New York (in an opinion authored by Judge Preska), inter alia, denied defendant’s motion to dismiss plaintiff’s race-based discriminatory termination claims. The court discussed, and applied, the…

Read More Actress Plausibly Alleges Race-Based Discriminatory Termination, Court Holds
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