Hostile Work Environment

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In Gahfi v. New York City Department of Education & Shenean Lindsay, No. 23-CV-1782 (BMC), 2026 WL 141907 (E.D.N.Y. Jan. 20, 2026), the court, inter alia, denied defendants’ motion for summary judgment on plaintiff’s hostile work environment claims under the New York State and City Human Rights Laws. From the decision: To survive a motion…

Read More Hostile Work Environment Claims, Arising in Part from Leave Request Denial, Survives Summary Judgment
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In Petrie v. New York State Office of Mental Health Central New York Psychiatric Center, No. 6:22-CV-123 (ECC/ML), 2026 WL 161198 (N.D.N.Y. Jan. 21, 2026), the court, inter alia, denied defendants’ motion for summary judgment on plaintiff’s hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. From the decision:…

Read More Title VII Hostile Work Environment Sexual Harassment Claim Survives Summary Judgment
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In Duckett-Holmes v. Planned Parenthood of Greater New York, Inc., No. 159488/2024, 2026 WL 93691 (N.Y. Sup. Ct. Jan. 05, 2026), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s hostile work environment claim. This decision illustrates the basic principles governing the pleading of such a claim: In order to state a claim for…

Read More Hostile Work Environment Claim Dismissed; “Bare Legal Conclusions” Insufficient to State a Claim
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In White v. Children’s Network of Southwest Florida LLC, No. 2:24-CV-00697-KCD-NPM, 2026 WL 98768 (M.D. Fla. Jan. 14, 2026), the court, inter alia, granted defendants’ motion to dismiss plaintiff’s hostile work environment claim. From the decision: As for the hostile work environment claim, employers can be liable when, despite not taking any tangible adverse action,…

Read More Age-Based Hostile Work Environment (ADEA( Claim Dismissed; “Old” Comments Insufficient to State a Claim
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In Poteat v. CP Development et al, No. 24-3290, 2026 WL 93129 (3d Cir. Jan. 13, 2026), the U.S. Court of Appeals for the Third Circuit affirmed a lower court’s granting of defendants’ motion to dismiss plaintiff’s claims of race discrimination and hostile work environment under 42 U.S.C. § 1981. The court summarized the facts,…

Read More Third Circuit Affirms Dismissal of Race Discrimination Claims Asserted Under 42 U.S.C. § 1981
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In Dorio v. Cmty. Hous. Mgmt. Corp. et al, No. 62784/2025, 2026 WL 90179 (N.Y. Sup. Ct. Jan. 8, 2026), the court, inter alia, granted defendants’ motion to dismiss plaintiff’s hostile work environment claim asserted under the New York State Human Rights Law. Among other things, plaintiff alleged that she was forced to endure a…

Read More Court Dismisses Scent-Based Hostile Work Environment Claim
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In Garcia v. ECPI Univ. LLC, No. 2:25-CV-245, 2026 WL 66749 (E.D. Va. Jan. 8, 2026), the court held that plaintiff alleged a “sexual harassment dispute” under the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 (EFAA), and thus denied defendant’s motion to compel arbitration of plaintiff’s claim under Title IX…

Read More Sexual Harassment Claim Stated Under Title IX; Motion to Compel Arbitration Denied Under EFAA
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In Draghi v. New York City Department of Education, No. 24-CV-2920 (EK)(MMH), 2026 WL 73970 (E.D.N.Y. Jan. 9, 2026), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s claim of hostile work environment asserted under the Americans with Disabilities Act (ADA). From the decision: To allege a hostile work environment, “a plaintiff must show…

Read More Disability-Based Hostile Work Environment Claim, Asserted Under ADA, Dismissed
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In Panchumarthi v. Tech Mahindra, No. 4:24-CV-01017-SDJ-BD, 2025 WL 3687142 (E.D. Tex. Dec. 15, 2025), the court held that the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act (EFAA) did not apply to plaintiff’s claims of discrimination (as opposed to sexual harassment). From the decision: Although the EFAA carves out some sex-discrimination claims,…

Read More Sexual Harassment Not Alleged; EFAA Did Not Apply to Sex Discrimination Claims
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In Ramirez v. City of New York, No. 24-CV-1061 (AS), 2026 WL 18678 (S.D.N.Y. Jan. 2, 2026), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s retaliation (but not disability discrimination) claim under the Rehabilitation Act. From the decision: The test for retaliation under the Rehabilitation Act has four parts: (1) the…

Read More Retaliation Claim, Based on Denial of Accommodations Following Filing of Lawsuit, Survives Summary Judgment
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