In Brooks v. Bright Horizons Family Solutions, Inc., et al, No. 25-1830-CV, 2026 WL 1660493 (2d Cir. June 9, 2026), the U.S. Court of Appeals for the Second Circuit reversed a lower court decision, and held that plaintiff plausibly alleged race discrimination in the form of termination and failure to promote under Title VII of…
Read More Second Circuit Reverses Dismissal of Race-Based Discrimination ClaimsIn Laghari v. State of Connecticut Department of Correction, No. 3:25-CV-1373-(VAB), 2026 WL 1622989 (D. Conn. June 5, 2026), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s hostile work environment claims, based on race and national origin, asserted under Title VII of the Civil Rights Act of 1964. From the decision: [Plaintiff] argues…
Read More Title VII Race, National Origin Discrimination Hostile Work Environment Claims Survive DismissalIn Thomasson v. State ex rel. Bd. of Regents of Nevada Sys. of Higher Educ., No. 3:25-CV-00611-MMD-CLB, 2026 WL 1346640 (D. Nev. May 13, 2026), the court granted defendant’s motion to dismiss plaintiff’s hostile work environment claims asserted under Title VII of the Civil Rights Act of 1964. From the decision: Defendant moves to dismiss…
Read More Title VII Hostile Work Environment Complaint Dismissed For Failure to Satisfy Rule 8’s “Short and Plain Statement” RequirementIn White v. Harvard Security, LLC, No. 25-CV-0622, 2026 WL 1413549 (E.D. Pa. May 19, 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: Title VII provides in relevant part that, “it shall be…
Read More Title VII Race-Based Hostile Work Environment Claim DismissedIn Brown v. CBS News, Inc., No. 152570/2025, 2026 WL 1348982 (N.Y. Sup. Ct. May 10, 2026), the court, inter alia, summarized and applied the law governing the geographic applicability of the New York State and City Human Rights Laws. It summarized the black-letter law as follows: The NYSHRL and NYCHRL each separately prohibit employment…
Read More Court Dismisses NYS and NYC Human Rights Law Claims on Subject Matter Jurisdiction Grounds; Relevant Conduct Occurred Outside New YorkIn Damptey v. Truist Bank, No. 6:26-CV-00050, 2026 WL 1358740 (W.D. Va. May 14, 2026), the court granted defendant’s motion to dismiss plaintiff’s complaint alleging a race-based hostile work environment in violation of Title VII of the Civil Rights Act of 1964. This decision illustrates the context-specific analysis required in these types of cases. From…
Read More Title VII Race-Based Hostile Work Environment Claim Dismissed; Alleged Use of Term “Cotton Picking” InsufficientIn Burgess v. Alamo Drafthouse et al, No. CV 25-02640 (AHA), 2026 WL 1070905 (D.D.C. Apr. 20, 2026), the court held that plaintiff failed to state a claim for age or race discrimination respectively under the Age Discrimination in Employment Act (ADEA) and Title VII of the Civil Rights Act of 1964. From the decision:…
Read More Age, Race Discrimination Claims Dismissed Against Alamo DrafthouseIn Claybrook v. Freightliner of Arizona, LLC et al, No. 3:25-CV-00633, 2026 WL 1195852 (M.D. Tenn. May 1, 2026), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s claim of hostile work environment sexual harassment asserted under Title VII of the Civil Rights Act of 1964. From the decision: To succeed on a hostile…
Read More Title VII Hostile Work Environment Sexual Harassment Claim Survives Dismissal; Racial Harassment Allegations Deemed Pertinent to PervasivenessIn Ashleigh, Theophania v. The Mount Sinai Hospital, 2026 WL 1133711 (S.D.N.Y. April 27, 2026), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s constructive discharge claim asserted under 42 U.S.C. § 1981. From the decision: Constructive discharge of an employee occurs when an employer, rather than directly discharging an individual, intentionally creates an…
Read More Race-Based Constructive Discharge Claim Sufficiently Alleged