Pleading

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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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In Samah v. Takeda Pharmaceuticals U.S.A., Inc., No. 1:25-CV-10158-JEK, 2026 WL 63399 (D. Mass. Jan. 8, 2026), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s race-based hostile work environment claims. From the decision: Counts 5 and 9 assert that Takeda violated Title VII and Chapter 151B, respectively, by subjecting Samah to a racially…

Read More Race-Based Hostile Work Environment Claims Survive Dismissal
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In Garcia v. ECPI Univ. LLC, No. 2:25-CV-245, 2026 WL 66749 (E.D. Va. Jan. 8, 2026), the court held that plaintiff alleged a “sexual harassment dispute” under the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 (EFAA), and thus denied defendant’s motion to compel arbitration of plaintiff’s claim under Title IX…

Read More Sexual Harassment Claim Stated Under Title IX; Motion to Compel Arbitration Denied Under EFAA
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In Keenan v. Bloomberg L.P., 2025 NY Slip Op 07224 (N.Y. App. Div. 1st Dept. Dec. 23, 2025), the court affirmed the lower court’s denial of defendant’s motion to dismiss plaintiff’s complaint alleging employment discrimination (including on disparate treatment and disparate impact theories). As to plaintiff’s disparate treatment claims, the court explained: Initially, we reject…

Read More Age, Sex Discrimination Claims Sufficiently Alleged Against Bloomberg L.P.
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In O’Connor v. Citigroup Global Markets, Inc., No. 158198/2024, 2025 WL 3709253 (N.Y. Sup. Ct. Dec. 17, 2025), the court, inter alia, held that plaintiff failed to state a claim of sex discrimination under the New York City Human Rights Law. After determining that plaintiff not receiving a promotion constituted an “adverse employment action,” it…

Read More Sex Discrimination Claims Against Citigroup Dismissed
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In Sheehan v. Everstory Partners et al, No. CV 24-6581, 2025 WL 3727863 (E.D. Pa. Dec. 23, 2025), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s hostile work environment sexual harassment claims. As to one plaintiff, the court explained: Defendants argue that the Amended Complaint fails to allege the first element of a…

Read More Hostile Work Environment Sexual Harassment Claims Survive Dismissal
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In Ibrahim v. Marco A. Rubio, No. 1:24-CV-02915 (TNM), 2025 WL 3718637 (D.D.C. Dec. 23, 2025), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s age discrimination claim asserted under the Age Discrimination in Employment Act (ADEA). From the decision: Ibrahim states a plausible ADEA claim. He is 65 years old. Compl. ¶ 47.…

Read More U.S. Embassy Employee Plausibly Alleges ADEA Age Discrimination Claim, Court Holds
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In Quinn v. Austin, No. CV 24-10285-NMG, 2025 WL 2841890 (D. Mass. Oct. 7, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: In support of a hostile work environment claim in this case, Quinn…

Read More Hostile Work Environment Claim Dismissed, Notwithstanding Confederate Flag Allegation
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