National Origin Discrimination

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From Chong v. The City of New York, No. 161606/2018, 2020 WL 3104355, 2020 N.Y. Slip Op. 31827(U) (N.Y. Sup Ct, New York County June 11, 2020) (J. Bluth): A close reading of plaintiff’s amended complaint reveals that plaintiff seems to have many grievances towards his co-workers and supervisors, including a complaint that OLR’s employees…

Read More Race, National Origin Discrimination Complaint Dismissed; Non-Detailed Events That “Almost Happened” Insufficient
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In Skariah v. The City of New York et al, No. 153189/2013, 2020 WL 3317000 (N.Y. Sup Ct, New York County June 18, 2020), the court, inter alia, granted defendants’ motion for summary judgment dismissing plaintiff’s national origin-based hostile work environment claim under the New York City Human Rights Law. The court summarized the law…

Read More Hostile Work Environment Claim Dismissed; Plaintiff Not “Treated Less Well” Because of National Origin
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In Shukla v. Deloitte Consulting LLP, 2020 WL 3181785 (S.D.N.Y. June 15, 2020), the court held, inter alia, that plaintiff sufficiently alleged race/national origin discrimination under the New York City Human Rights Law. The court also dismissed several of plaintiff’s other claims, including his gender, race and national origin discrimination claims under Title VII, Section…

Read More Citing “Expendable Indian” Comment, Court Finds Plaintiff Plausibly Alleged Race/National Origin Discrimination Claim Under the NYC Human Rights Law
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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 Matthew v. JPMorgan Chase Bank, N.A., 2020 WL 2523064 (EDNY May 18, 2020) (J. Mauskopf), the court, inter alia, dismissed plaintiff’s national origin-based hostile work environment claim. From the decision: [Plaintiff] Matthew has not alleged any facts supporting an inference that she was terminated because of her race or gender. Indeed, the only allegation…

Read More Accent-Based National Origin Hostile Work Environment Claim Dismissed Against JPMorgan Chase
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From Mohan v The City of New York, No. 151018/2019, 2020 WL 1546404, 2020 N.Y. Slip Op. 30729(U), 5 (N.Y. Sup Ct, New York County Mar. 03, 2020): As it pertains to plaintiff’s claims of discrimination, the court finds that plaintiff has not proffered evidence suggesting that on the basis of her race, gender, or…

Read More Race, Gender, National Origin Discrimination Claims Dismissed Against City of New York
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The U.S. Equal Employment Opportunity Commission (EEOC), which enforces various federal anti-discrimination laws (including Title VII of the Civil Rights Act of 1964) has recently reaffirmed its commitment to addressing and remedying discrimination arising from or relating to the COVID-19 situation. From the EEOC chair: Crises like the COVID-19 pandemic can bring out the best…

Read More EEOC on COVID19-Based Race and National Origin Discrimination
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In Jian Hua Li v. Chang Lung Group Inc., 2020 WL 1694356 (E.D.N.Y. April 7, 2020), the court, inter alia, dismissed plaintiff’s hostile work environment claims asserted under the New York State and City Human Rights Laws. As to plaintiff’s state law claim, the court explained: Plaintiff’s hostile work environment claim under the NYSHRL fails.…

Read More Hostile Work Environment Claim, Based on Chinese-American Status, Dismissed
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In Kiraka v. M&T Bank, 2020 WL 1285632 (N.D.N.Y. March 18, 2020), the court, inter alia, dismissed plaintiff’s hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. After summarizing the black-letter law regarding such claims, the court explained: [Plaintiff] fails to state a plausible claim under Title VII. ……

Read More Hostile Work Environment Claim Dismissed; Allegations, Including Mocking of Accent, Held Insufficient
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In Eyuboglu v. Gravity Media, LLC, 2020 WL 1280675 (2d Cir. March 17, 2020) (Summary Order), the court affirmed the dismissal of plaintiff’s employment discrimination claims under Title VII of the Civil Rights Act of 1964. The court based its decision, in part, on the so-called “stray marks” doctrine: “While discriminatory remarks may constitute evidence of…

Read More Citing “Stray Remarks” Doctrine, 2d Circuit Affirms Dismissal of Employment Discrimination Claims
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