Hostile Work Environment

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In Jean-Pierre v. City of New York, No. 153859/2023, 2024 WL 4753498 (N.Y. Sup Ct, New York County Nov. 12, 2024), the court denied defendant’s motion to dismiss plaintiff’s claims of race discrimination and hostile work environment. From the decision: Plaintiff’s amended complaint alleges sufficient facts to support claims of discrimination and hostile work environment…

Read More Race-Based Discrimination & Hostile Work Environment Claims Sufficiently Alleged Against City of New York, Court Holds
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In Robinson v. District of Columbia, 2024 WL 4722157 (D.D.C. Nov. 8, 2024), the court, inter alia, dismissed plaintiff’s claim of race-based hostile work environment asserted under Title VII of the Civil Rights Act of 1964. After explaining that plaintiff failed to plead a timely hostile work environment claim, the court continued: Plaintiff’s hostile work…

Read More Title VII Race-Based Hostile Work Environment Claim Dismissed Against the District of Columbia
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In Hatcher v. New York City Department of Education, 23-cv-3510 (NRM) (LB), 2024 WL 4333643 (E.D.N.Y. Sept. 27, 2024), the court, inter alia, held that plaintiff sufficiently alleged a race-based hostile work environment claims under Title VII of the Civil Rights Act of 1964, the New York State Human Rights Law, and the New York…

Read More Speech Therapy Teacher Sufficiently Alleges Race-Based Hostile Work Environment, Court Holds
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In Allen v. New York State et al, 2:24-cv-02800 (JS) (JMW), 2024 WL 4654220 (E.D.N.Y. Nov. 1, 2024), the court denied defendants’ motion to stay this action in which plaintiff asserts claims of hostile work environment, sexual harassment, and retaliation. After summarizing the legal standard and the factors considered by courts – namely, “(1) whether…

Read More Court Declines to Stay Hostile Work Environment Sexual Harassment Case
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In Murray v. Brag Sales Inc. d/b/a Uneeda Enterprises et al, 2024 WL 4635479 (S.D.N.Y. Oct. 31, 2024), the court denied plaintiff’s motion for reconsideration of the dismissal of his claim of employment discrimination asserted under the New York City Human Rights Law. This decision is instructive on the geographic reach of that statute. From…

Read More Court Upholds Dismissal of NYCHRL Discrimination Claim; Plaintiff Worked Outside NYC
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In Goodwin v. UTGR, Inc., 2024 WL 4355044 (D.R.I. Sept. 30, 2024), the court, inter alia, denied defendant’s 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: Here, Mr. Goodwin has presented evidence in which a reasonable jury could conclude…

Read More Sexual Orientation-Based Hostile Work Environment Claim Survives Summary Judgment
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In Fernsmith v. City of New York, No. 158467/2023, 2024 WL 4604773 (N.Y. Sup Ct, New York County Oct. 29, 2024), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s disability-based hostile work environment claim asserted under the New York City Human Rights Law. From the decision: Under the CHRL, a hostile work environment…

Read More Disability-Based Hostile Work Environment Claim Sufficiently Alleged Against City of New York
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In Munck v. Simons Foundation, 2024 WL 4307776 (S.D.N.Y. Sept. 26, 2024), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s race-based hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. After determining that plaintiff did not allege any timely acts to “anchor” earlier related acts to enable…

Read More Hostile Work Environment Claim Dismissed; Only Timely Alleged Act Was Termination of Employee Outside Plaintiff’s Protected Class
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In Jesenia Villalobos v. Merrill Lynch, No. CV-24-02139-PHX-JJT, 2024 WL 4566852 (D.Ariz. Oct. 24, 2024), the court dismissed plaintiff’s hostile work environment claim asserted under Title VII of the Civil Rights Act 1964. After summarizing the black-letter law, the court applied it to the facts: In this case, the conduct complained of by Plaintiff was…

Read More Hostile Work Environment Sexual Harassment Claim Dismissed; Expressed Romantic Interest Was Not Sufficiently “Severe”
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In Moreno v. City of Porterville, Case No. 1:23-cv-00541-BAM, 2024 WL 4347302 (E.D.Cal. Sept. 30, 2024), the court, inter alia, granted defendants’ motion to dismiss plaintiff’s hostile work environment sexual harassment claims. After summarizing the black-letter law, the court applied it to the facts as follows: Plaintiff next contends that her allegations regarding Sokoloff’s conduct…

Read More Hostile Work Environment Sexual Harassment Claims Dismissed; Multiple Invitations Insufficient
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