Race / Color Discrimination

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In Holmes v. United States Steel Corporation, No. 2:23-CV-359-JEM, 2026 WL 2279295 (N.D. Ind. Aug. 6, 2026), the court, inter alia, dismissed plaintiff’s hostile work environment claim under Title VII of the Civil Rights Act of 1964, finding that plaintiff failed to “exhaust” that claim before the U.S. Equal Employment Opportunity Commission (EEOC). From the…

Read More Title VII Hostile Work Environment Claim Dismissed as Not Administratively Exhausted at the EEOC; Checking Box Held Insufficient
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In Bates v. Leviton Manufacturing Co., Inc., No. 3:24-CV-01414, 2026 WL 2211556 (M.D. Tenn. July 31, 2026), the court, inter alia, granted defendant’s motion for summary judgment on plaintiff’s claim of race-based hostile work environment asserted under Title VII of the Civil Rights Act of 1964. Among other allegations was that another employee told plaintiff…

Read More Title VII Race-Based Hostile Work Environment Claim Dismissed; Rumor of “Slave” Comment Insufficient
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In Licea v. Illinois Cent. Ry. Co., No. 1:25-CV-08706, 2026 WL 2049497 (N.D. Ill. July 15, 2026), the court granted defendant’s motion to dismiss plaintiff’s complaint alleging employment discrimination under Title VII of the Civil Rights Act of 1964. In sum, plaintiff, a journeyman machinist, alleges that her foreman “verbally and sexually harassed” her. This…

Read More Court Dismisses Complaint Alleging Race & Sex Discrimination Under Title VII
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In Brenyah v. Columbia Hosp. Corp. of Bay Area, No. 25-40200, 2026 WL 2023814 (5th Cir. July 14, 2026), the court, inter alia, reversed a lower court’s award of summary judgment to defendant on plaintiff’s claims of race-based hostile work environment claims under Title VII of the Civil Rights Act of 1964 and 42 U.S.C.…

Read More Race-Based Hostile Work Environment Claims Survive Summary Judgment; Dismissal Reversed
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In Cadet v. Macy’s, Inc., No. 22-CV-7406 (VSB), 2026 WL 1998595 (S.D.N.Y. July 10, 2026), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s claims of race and national origin-based hostile work environment. As to the issue of whether the alleged conduct was sufficiently “severe” or “pervasive” under 42 USC § 1981…

Read More Race, National Origin Based Hostile Work Environment Claims Against Macy’s Survive Summary Judgment
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In Miller v. Markwayne Mullin et al, No. 1:25-CV-00703-JRR, 2026 WL 1861955 (D. Md. June 29, 2026), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s race-based hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: Here, Defendant argues all the alleged discrete discriminatory incidents…

Read More Race-Based Hostile Work Environment Claim Dismissed; Evidence, Including Monkey Emoji, Insufficient
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In Walker v. CSL Plasma, Inc., No. 6:22-CV-6413-CJS-CDH, 2026 WL 1596200 (W.D.N.Y. June 4, 2026), the court granted defendants’ motion for summary judgment on plaintiff’s claim of retaliation under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 1981, and the New York State Human Rights Law. This case is instructive as…

Read More Retaliation Claims Dismissed on Summary Judgment; Complaint Did Not Involve Accusation of Racism
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In Gordon v. Heath, No. 23-2232, 2026 WL 1811021 (4th Cir. June 24, 2026), the court affirmed the denial of qualified immunity in a case of a race-based hostile work environment asserted under Title VII of the Civil Rights Act of 1964 and 42 U.S.C. § 1981. The court summarized the facts as follows: Don…

Read More Race-Based Hostile Work Environment Claims Sufficiently Alleged, Fourth Circuit Holds
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Every year on June 19th, as New York City slows down just a bit to observe Juneteenth, I find myself looking out my office window and thinking about a painful historical truth. Juneteenth commemorates June 19, 1865 – the day Union Major General Gordon Granger arrived in Galveston, Texas, to enforce the Emancipation Proclamation. What…

Read More Delayed Justice, Subtle Discrimination: Why Juneteenth Hits Differently for an NYC Employment Lawyer
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In a recent decision involving a claim of race discrimination in employment under Title VII of the Civil Rights Act of 1964, Bravo v. Dallas Indep. Sch. Dist., No. 25-10982, 2026 WL 1531713 (5th Cir. June 1, 2026), the U.S. Court of Appeals for the Fifth Circuit concluded that, notwithstanding the Supreme Court’s recent decision…

Read More Fifth Circuit Finds That SCOTUS’ Ames Decision Did Not Alter Rule Requiring Evidence of a Similarly-Situated Comparator in Title VII Race Discrimination Case
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