Hostile Work Environment

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In Boliak v. Father Michael P. Reilly et al, No. 153941/16, 2025 WL 3672342 (N.Y. App. Div. 1 Dept. Dec. 18, 2025), the court, inter alia, held that the lower court improperly dismissed plaintiff’s hostile work environment claims under the “ministerial exception.” From the decision: Plaintiffs Boliak, Maureen Smith, and Thomas Rodes were all employed…

Read More Hostile Work Environment Claims Not Barred by the “Ministerial Exception”, First Department Holds
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In Bonafede v. Museum of Modern Art, No. 150557/2024, 2025 WL 3634707 (N.Y. Sup. Ct. Dec. 11, 2025), the court, inter alia, held that plaintiff sufficiently alleged a claim of hostile work environment under the New York City Human Rights Law. The court summarized the facts as follows: Bonafede brings this action as a result…

Read More MoMA Performer Sufficiently Alleges NYCHRL Hostile Work Environment Claim, Court Holds
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In White v. Board of Trustees of the University of Arkansas, No. 4:25-CV-00702-BSM, 2025 WL 3527401 (E.D. Ark. Dec. 9, 2025), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s hostile work environment claim asserted under the Americans with Disabilities Act (ADA). From the decision: Defendants’ motion to dismiss White’s ADA hostile work environment…

Read More ADA Hostile Work Environment Claim Survives Dismissal
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In Rizvi v. Loudoun County School Board, No. 1:25-CV-307-MSN-IDD, 2025 WL 3514256 (E.D. Va. Dec. 5, 2025), the court, inter alia, granted defendants’ motion to dismiss plaintiff’s hostile work environment claims based on age, race, color, national origin, and religion. From the decision: Defendant further seeks to dismiss Plaintiff’s claims of hostile work environment under…

Read More Age, Race, Color, National Origin, Religion-Based Hostile Work Environment Claims Dismissed
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In Risner v. Thomas E. Creek VA Med. Ctr., No. 2:24-CV-202-Z-BR, 2025 WL 2899903 (N.D. Tex. Oct. 10, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s claim of sexual harassment asserted under Title VII of the Civil Rights Act of 1964, on the ground that plaintiff failed to “exhaust administrative remedies.” From…

Read More Sexual Harassment Claims Not Administratively Exhausted at the EEOC, Court Holds
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In Myers v. Doherty, 2025 NY Slip Op 06550 (N.Y. App. Div. 1 Dept. Nov. 25, 2025), the court affirmed the lower court’s order granting defendants’ motion to dismiss plaintiff’s complaint alleging claims of employment discrimination, retaliation, and hostile work environment. From the decision: Plaintiff did not experience an adverse employment action when he was…

Read More Failure to Demonstrate Discriminatory Animus Dooms Discrimination, Retaliation, & Hostile Work Environment Claims, First Department Holds
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In Livingston-Willis v. Iberia Comprehensive Community Health Center Inc. et al, No. 6:25-CV-00954, 2025 WL 3457935 (W.D. La. Nov. 13, 2025), the court, inter alia, held that plaintiff failed to state a hostile work environment claim under Title VII of the Civil Rights Act of 1964. From the decision: In order to establish a hostile…

Read More Hostile Work Environment Claim Not Stated; Only “Passive” Conduct Alleged
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In Ghiorse v. John H. Cook, Jr. Painting Contractor, Inc. et al, No. 3:25-CV-1578 (BKS/MJK), 2025 WL 3465995 (N.D.N.Y. Dec. 2, 2025), the court, inter alia, recommended the the district court allow plaintiff’s hostile work environment claim under Title VII o the Civil Rights Act of 1964 to proceed against the entity defendant – but…

Read More Title VII Sex-Based Hostile Work Environment Claim Sufficiently Alleged; Status of Key Actor to be Clarified in Amended Complaint
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In Dorsey v. Iberia Comprehensive Community Health Center Inc. et al, No. 6:25-CV-00952, 2025 WL 3263883 (W.D. La. Nov. 6, 2025), the court held that plaintiff failed to state a sex-based hostile work environment claim under Title VII of the Civil Rights Act of 1964. From the decision: In order to establish a hostile working…

Read More Hostile Work Environment Claim Dismissed; “Disrespect” Insufficient
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In Estep v. Brenner, No. 159639/2022, 2025 WL 3312877 (N.Y. Sup. Ct. Nov. 24, 2025), the court denied plaintiff’s motion to amend their complaint to add a cause of action for race-based discrimination and hostile work environment under federal law (Title VII of the Civil Rights Act of 1964), following the dismissal of plaintiff’s claim…

Read More Motion to Amend Complaint to Add Title VII Race Discrimination, Hostile Work Environment Claims Denied
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