Hostile Work Environment

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In Rosalie v. Supreme Glass Co., Inc., 18-CV-02064, 2020 WL 6263311 (EDNY Oct. 23, 2020), the court, inter alia, denied defendants’ motion for summary judgment on plaintiff’s sexual orientation-based hostile work environment claims under Title VII of the Civil Rights Act of 1964 and the New York City Human Rights Law. The court outlined the…

Read More Hostile Work Environment (Sexual Orientation/Gender) Claims Survive Based on Offensive Comments
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In Langlois v. Hartford Board of Education et al, 2020 WL 6278722 (2d Cir. Oct. 27, 2020) (Summary Order), the court, inter alia, affirmed the dismissal on summary judgment of plaintiff’s race-based hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. The court wrote: [W]e agree with the district…

Read More Race-Based Hostile Work Environment Claim Properly Dismissed; Most Conduct Was “Reasonably Expected” in the School Environment
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In Cardwell v. Davis Polk & Wardwell LLP et al, 19-cv-10256, 2020 WL 6274826 (S.D.N.Y. Oct. 24, 2020), the court, inter alia, dismissed plaintiff’s race-based hostile work environment claim. In sum, plaintiff – a law firm associate – alleged (inter alia) that he was suffered a hostile work environment on account of his race, in…

Read More Race-Based Hostile Work Environment Claim Dismissed; Social Ostracism Insufficient
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In Lax v. City University of New York et al, 2020 WL 6161253 (EDNY Oct. 21, 2020), the court, inter alia, dismissed plaintiff’s hostile work environment claim. The court summarized the “black-letter law” as follows: A hostile work environment claim requires a showing: (1) that the harassment was “sufficiently severe or pervasive to alter the…

Read More Hostile Work Environment Claim Dismissed, as it was Largely Based on Conduct Experienced by Others
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Ordinarily I write about decisions issued by New York state courts, federal district courts located in New York, the U.S. Court of Appeals for the 2nd Circuit, and, of course, the U.S. Supreme Court. Here, however, I’ll make an exception and stray from these jurisdictional/geographic limits, in order to discuss a decision issued by the…

Read More “N-Word” Did Not Give Rise to Hostile Work Environment: SCOTUS-Nominee Amy Coney Barrett
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In Rodriguez v. County of Nassau, Nassau County Commission on Human Rights, 2020 WL 5948904 (2d Cir. Oct. 8, 2020) (Summary Order), the court, inter alia, affirmed the dismissal of plaintiff’s gender and national origin-based hostile work environment claim. After outlining the “black-letter law” relating to this claim, the court summarized plaintiff’s contentions: In support…

Read More Hostile Work Environment Claim Dismissal Affirmed; “Handful of Comments Made Over a Decade” Held Insufficient
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In Crump v. The New York City Housing Authority, No. 163138/2015, 2020 WL 5874852 (N.Y. Sup Ct, New York County Oct. 02, 2020), the court, inter alia, denied defendants’ motion for summary judgment on plaintiff’s claim that he was subject to discrimination and harassment based on his sexual orientation in violation of the New York…

Read More Sexual Orientation Discrimination / Harassment Claim Against NYC Housing Authority Survives Summary Judgment
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In Antoine v. Brooklyn Maids 26, Inc. et al, 19-cv-5676, 2020 WL 5752186 (E.D.N.Y. Sept. 26, 2020), the court, inter alia, awarded a sexual harassment plaintiff $200,000 in emotional distress damages (on default). This case involves shocking allegations of harassment, including on one occasion conduct that the court described as “tantamount to rape.” As to…

Read More $200,000 Emotional Distress Award in Sexual Harassment Case Against Brooklyn Maids 26, Inc. and Individual Defendant
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In Ramirez v. Michael Cetta Inc. d/b/a Sparks Steak House LLC, 2020 WL 5819551 (SDNY Sept. 30, 2020), the court, inter alia, dismissed plaintiff’s sex/gender-based hostile work environment (sexual harassment) claims. Plaintiff alleged, among other things, that the discriminatory conduct included “(1) her coworkers calling her a bitch on a single occasion; (2) her coworker…

Read More Hostile Work Environment Sexual Harassment Claims Dismissed Against Sparks Steakhouse
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In Antoine v. Brooklyn Maids 26, Inc. et al, 19-cv-5676, 2020 WL 5752186 (E.D.N.Y. Sept. 26, 2020), the court, inter alia, held that plaintiff sufficiently alleged hostile work environment sexual harassment against defendants, and therefore granted plaintiff’s motion for a default judgment. From the decision: Plaintiff’s hostile work environment claim hinges primarily on two incidents.…

Read More Sexual Harassment/Hostile Work Environment Claim Sufficiently Alleged Against Brooklyn Maids 26, Inc. and Individual Defendant
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