Hostile Work Environment

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In Wilson v. Ciocca Muncy Ho Inc., No. 4:23-CV-00765, 2023 WL 6449425 (M.D.Pa. Oct. 3, 2023), the court, inter alia, held that plaintiff administratively exhausted certain claims, but not others, in her charge filed at the U.S. Equal Employment Opportunity Commission (EEOC). In sum, plaintiff alleges that she experienced sex discrimination (including sexual harassment), racial…

Read More Claims, Including For Sex Discrimination & Hostile Work Environment Sexual Harassment, Were Administratively Exhausted at the EEOC, Court Holds
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In Williams v. Inspira Health Network, 2023 WL 7151222 (D.N.J. Oct. 31, 2023), the court, inter alia, granted defendant’s motion for summary judgment dismissing plaintiff’s hostile work environment sexual harassment claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: Defendant argues that “[s]ummary judgment on Plaintiff’s NJLAD and Title…

Read More Title VII Sexual Harassment Complaint Dismissed; Alleged Comments and Touching Hair Was Not “Severe” or “Pervasive”
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In Achee v. Incorporated Village of Valley Stream et al, No. 20-cv-5294, 2023 WL 7130717 (E.D.N.Y. Oct. 30, 2023), the court, inter alia, denied motion for summary judgment on plaintiff’s 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 Human Rights…

Read More Race, Religion-Based Hostile Work Environment Claims Survive Summary Judgment; Evidence Included Threat to “Hang” Plaintiff
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The old saying that “the devil is in the details” applies, with especial force, to hostile work environment sexual harassment claims. That said, as one court recently explained, the work environment need not be “hellish” in order to make out a claim. In Brinson v. Eagle Express Lines, Inc., No. 18-cv-3733, 2023 WL 6312400 (N.D.Ill.…

Read More Sexual Harassment Claim Survives Summary Judgment; “Hellishness” Not Required
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In Wilson et al v. City of Greenville, Mississippi et al, No. 4:22CV64-GHD-DAS, 2023 WL 7021295 (N.D.Miss. Oct. 25, 2023), the court, inter alia, denied defendants’ motion for judgment on the pleadings as to plaintiffs’ claims of retaliatory hostile work environment asserted under Title VII of the Civil Rights Act of 1964. From the decision:…

Read More Title VII Retaliatory Hostile Work Environment Claim Survives Dismissal; Alleged Harassment Occurred Shortly After EEOC Charge
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In Wilson et al v. City of Greenville, Mississippi et al, No. 4:22CV64-GHD-DAS, 2023 WL 7021295 (N.D.Miss. Oct. 25, 2023), the court, inter alia, denied defendants’ motion for judgment on the pleadings as to plaintiffs’ claims of hostile work environment based on sex and sexual orientation asserted under Title VII of the Civil Rights Act…

Read More Title VII Hostile Work Environment Sexual Harassment Claim Survives Dismissal; Allegations Include Remarks About Sexual Orientation
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In Bethea v. First-Citizens Bank & Trust Company, 2023 WL 6284425 (D.S.C. Sept. 27, 2023), the court, inter alia, granted the defendant’s motion to dismiss plaintiff’s hostile work environment claim, asserted under Title VII of the Civil Rights Act of 1964, on the ground that it was not “administratively exhausted” at the U.S. Equal Employment…

Read More Title VII Hostile Work Environment Claim Dismissed as Not “Administratively Exhausted” at the EEOC
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In Schlosser v. Vrhabilis, LLC, 2023 WL 6881044 (E.D.Tenn. Oct. 18, 2023), the court denied defendant’s motion for judgment as a matter of law on plaintiff’s sex-based hostile work environment claim in violation of Title VII of the Civil Rights Act o 1964. From the decision: In this case, Schlosser proffered sufficient evidence from which…

Read More Sex-Based Hostile Work Environment Claim Survives Post-Verdict Motion; Evidence Included Unequal Treatment & Verbal Abuse
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In Beran v. VSL North Platte Court LLC, No. 7:21CV5003, 2023 WL 6880146 (D.Neb. Oct. 18, 2023), the court, inter alia, upheld a jury verdict finding in plaintiff’s favor on her hostile work environment sexual harassment claim asserted under Title VII of the Civil Rights Act of 1964. In finding that the evidence of a…

Read More Sexual Harassment Jury Verdict Upheld; Evidence Included Groping of Butt, Breasts
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In Walker v. Triborough Bridge and Tunnel Authority et al, No. 160839/21, 2022-04246, 2023 N.Y. Slip Op. 05344, 2023 WL 6884130 (N.Y.A.D. 1 Dept., Oct. 19, 2023), the Appellate Division, First Department unanimously affirmed the trial court’s Order denying defendants’ motion to dismiss plaintiff’s causes of action for discrimination and retaliation under the New York…

Read More Discrimination, Hostile Work Environment, Retaliation, Gender-Motivated Violence Act, Aiding & Abetting Claims Survive Dismissal Against Triborough Bridge & Tunnel Authority
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