Hostile Work Environment

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In Schaffer v. GeneDx, LLC et al, No. 25 CIV. 2550 (DEH) (GS), 2026 WL 265338 (S.D.N.Y. Jan. 30, 2026), the court, inter alia, recommended that defendant’s motion to dismiss plaintiff’s sex-based hostile work environment claim under Title VII of the Civil Rights Act of 1964 be granted. From the decision: Even accepting Schaffer’s allegations…

Read More Sex-Based Hostile Work Environment Not Plausibly Alleged, Notwithstanding Micromanagement Allegations
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In McGinnis v. Plamondon Enterprises, Inc. d/b/a Roy Rogers, No. 25-2138-BAH, 2026 WL 221694 (D. Md. Jan. 28, 2026), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s sex-based hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: Plaintiff plainly alleges the first…

Read More Sex-Based Hostile Work Environment Claims Survive Dismissal; Allegations Included “Repeated” Restroom Entry
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In Burgess v. MTA Const. and Development Co., No. 160414/2024, 2026 WL 195519 (N.Y. Sup. Ct. Jan. 21, 2026), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s hostile work environment claims asserted under the New York State and City Human Rights Laws. From the decision: To plead a hostile work environment marred with…

Read More Hostile Work Environment Claims Survive Dismissal; Allegations Include Questioning About Sexual Orientation, Race, and Medical Condition
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In Santana v. Telemundo Network Group, LLC et al, No. 22-13879, 2026 WL 180272 (11th Cir. Jan. 22, 2026), the U.S. Court of Appeals for the Eleventh Circuit held that summary judgment was improper on plaintiff’s sexual harassment claim under, e.g., Title VII of the Civil Rights Act of 1964. From the decision: Santana presented…

Read More Eleventh Circuit Revives Title VII Hostile Work Environment Sexual Harassment Claim From Summary Judgment Dismissal
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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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