Hostile Work Environment

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A recently-issued Consent Decree in the matter of EEOC v. GRK Pas LLC d/b/a GRK Fresh Greek, 2020 WL 3073786 (S.D.N.Y. June 10, 2020) reflects the resolution of plaintiffs’ hostile work environment sexual harassment claims asserted under Title VII of the Civil Rights Act of 1964. From the Decree: Considering Defendants’ ongoing financial difficulties. the…

Read More EEOC Consent Decree Reached with GRK Fresh Holdings in Sexual Harassment Case
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In Howell v. United Federation of Teachers Welfare Fund, No. 153234/2017, 2020 WL 2933631, 2020 N.Y. Slip Op. 31713(U) (N.Y. Sup Ct, New York County June 03, 2020), the court, inter alia, granted defendants’ motion for summary judgment on plaintiff’s hostile work environment claim under the New York State and City Human Rights Laws. As…

Read More Hostile Work Environment Claims Dismissed Against United Federation of Teachers Welfare Fund
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In Sooroojballie v. Port Authority of New York & New Jersey, 2020 WL 2988851 (2d Cir. June 4, 2020) (Summary Order), the Second Circuit, inter alia, held that the jury’s emotional damages awarded by the jury ($2,160,000) on plaintiff’s race- and national origin-based hostile work environment claim was excessive, and determined that $250,000 was more appropriate.…

Read More Court Remits $2.16 Million Jury Verdict to $250,000 in Race/National Origin Hostile Work Environment Case
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In Mejia v. City of New York, 2020 WL 2837008 (E.D.N.Y. May 30, 2020), the court, inter alia, denied defendants’ motion for summary judgment on plaintiff’s hostile work environment claim asserted against two individuals under the New York City Human Rights Law. From the decision: Plaintiff’s gender-based hostile work environment claim, however, is viable as…

Read More “Bitch” Remark Among Evidence Supporting Denial of Summary Judgment Under the NYC Human Rights Law on Plaintiff’s Hostile Work Environment Claim
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In Rivera v. JP Morgan Chase, 2020 WL 2787622 (2d Cir. May 29, 2020) (Summary Order), the U.S. Court of Appeals for the Second Circuit, inter alia, affirmed the dismissal of plaintiff’s race- and national origin-based hostile work environment claim under Title VII of the Civil Rights Act of 1964. From the decision: To state…

Read More Hostile Work Environment Claim Dismissal Affirmed; Insufficient Details Alleged
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In Gold v. Titlevest Agency LLC, et al., Defendants., 2020 WL 2835570 (S.D.N.Y. June 1, 2020), the court, inter alia, granted defendants’ motion for summary judgment on plaintiff’s gender-based hostile work environment claims under Title VII and the New York State and City Human Rights Laws. In sum, plaintiff alleged (among other things) that her…

Read More “Hearsay”-Based Hostile Work Environment Claim Dismissed
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In Erno v. New York State Office of Information Technology Services, 19-CV-1457, 2020 WL 2736563 (N.D.N.Y. May 26, 2020), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s hostile work environment sexual harassment claim. From the decision: Considered in totality, the Court finds that the facts alleged by Plaintiff are sufficient to state a hostile…

Read More Hostile Work Environment Sexual Harassment Claim Sufficiently Alleged; Allegations Included Sexist Jokes
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In Williams v. County of Nassau, 2020 WL 2703675 (2d Cir. May 26, 2020)) (Summary Order), the Second Circuit, inter alia, affirmed the lower court ‘s summary judgment dismissal of plaintiff’s hostile work environment claim. From the decision: [T]he existence of the carvings at issue, though highly offensive, were not under the specific circumstances here…

Read More Hostile Work Environment Dismissal Affirmed; Alleged Racist Etchings Insufficient
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In Pardovani v. Crown Building Maintenance Co., 2020 WL 2555280 (SDNY May 20, 2020), the court denied defendants’ motion for summary judgment on plaintiff’s race-based hostile work environment claim. From the decision: Pardovani offers evidence to suggest that, far from an occasional occurrence, the word “nigger,” and derivations thereof, were used frequently and offensively in…

Read More Race-Based Hostile Work Environment Claims Survive; Evidence Included the Use of the “N-Word”
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In Bateman v. Montefiore Med. Ctr., 2020 NY Slip Op 02969 (App. Div. 1st Dept. May 21, 2020), the court unanimously modified a lower court Order so as to deny defendants’ motion for summary judgment dismissing plaintiff’s claims for employment discrimination, hostile work environment, and retaliation under the New York State and City Human Rights Laws.…

Read More Race Discrimination, Hostile Work Environment, Retaliation Claims Resurrected From Summary Judgment Dismissal Against Montefiore Medical Center
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