In Sean C.I.R. v. Nexstar Media Group Inc., No. 150543/2024, 2025 WL 944582, 2025 N.Y. Slip Op. 30975(U), 7–8 (N.Y. Sup Ct, New York County Mar. 28, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s claims of a race-based hostile work environment under the New York State and City Human Rights Laws.…
Read More Race-Based Hostile Work Environment Claims DismissedIn Smith v. National Grid USA, 2:21-cv-6899 (NJC) (LGD), 2025 WL 1248676 (E.D.N.Y. April 30, 2025), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s race-based hostile work environment claims. From the decision: [T]here are numerous genuine disputes of material fact concerning Smith’s hostile work environment claims—under both the higher federal standard…
Read More Race-Based Hostile Work Environment Claims Survive Summary Judgment; Allegations Include “Shine Box” and “Monkey” CommentsIn Smart, Kathyann v. USA Labor for Hire, Inc., RC Global Energy Group, Inc., Oleg Tsimbler, No. 24-1791, 2025 WL 1217365 (2d Cir. April 28, 2025), the U.S. Court of Appeals for the Second Circuit, inter alia, affirmed the lower court’s denial of defendant’s motion for new trial or remittitur on plaintiff’s claims of hostile…
Read More 2nd Circuit Holds That Jury Properly Found Hostile Work Environment, Based on Racially Derogatory and Sexist Language,In Huaman v. United Airlines, Inc., No. 160784/2023, 2025 WL 1158984 (N.Y. Sup Ct, New York County Apr. 21, 2025), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s complaint asserting employment discrimination under the New York State and City Human Rights Laws. From the decision: Defendants’ motion to dismiss pursuant to CPLR 3211(a)(7)…
Read More Motion to Dismiss NYSHRL & NYCHRL Discrimination Claims Denied; “Impact” Test SatisfiedIn Browne v. New York State Department of Corrections and Community Supervision, 2025 WL 1177958 (2d Cir. April 23, 2025), the U.S. Court of Appeals for the Second Circuit affirmed the district court’s award of summary judgment to the defendant on plaintiff’s claim of a race-based hostile work environment under Title VII of the Civil…
Read More Hostile Work Environment Claim Properly Dismissed; Allegedly “Racially Offensive” Poems InsufficientIn Gildyard v. Children’s Network of Southwest Florida, LLC, Case No.: 2:24-cv-702-SPC-KCD, 2025 WL 1093331 (M.D.Fla. April 10, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s race-based hostile work environment claim, on the ground that plaintiff failed to “administratively exhaust” that claim at the U.S. Equal Employment Opportunity Commission. From the decision:…
Read More Race-Based Hostile Work Environment Claim Dismissed on “Administrative Exhaustion” GroundsIn Knox v. CRC Management Co., LLC, No. 23-121, 2025 WL 1057862 (2d Cir. April 9, 2025), the U.S. Court of Appeals for the Second Circuit, inter alia, vacated a lower court Order dismissing plaintiff’s claims, on summary judgment, of race- and national origin-based termination. From the decision: Knox alleges that Clean Rite’s decision to…
Read More Race, National Origin Discrimination Claims Survive Summary Judgment, 2nd Circuit FindsIn Young v. Bessemer Trust Co., N.A, No. 154722/2020, 2025 WL 928439 (N.Y. Sup Ct, New York County Mar. 25, 2025), the court, inter alia, denied defendants’ motion for summary judgment on plaintiff’s race/national origin discrimination claims asserted under the New York State and City Human Rights Laws. From the decision: The Court finds that…
Read More Race/National Origin Discrimination Claims Survive Summary Judgment; “Wuhan Restriction Zone” Sign CitedIn Pierluissi v. City of New York, No. 153439/2023, 2025 WL 928908 (N.Y. Sup Ct, New York County Mar. 26, 2025), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s race discrimination claims under the New York State and City Human Rights Laws. From the decision: Both the NYSHRL and NYCHRL make it unlawful…
Read More Race Discrimination Claims Sufficiently Alleged; “Dumb Spic” Comments Supported ClaimIn Pierluissi v. City of New York, No. 153439/2023, 2025 WL 928908 (N.Y. Sup Ct, New York County Mar. 26, 2025), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s race & national origin-based hostile work environment claims asserted under the New York State and City Human Rights Laws. In general, plaintiff alleges that defendants…
Read More Hostile Work Environment Claims, Based on Race & National Origin, Survive Dismissal