Race / Color Discrimination

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In Allen v. City of New York et al, 18-cv-9663, 2020 WL 4287361 (SDNY July 27, 2020), the court, inter alia, dismissed plaintiff’s complaint alleging a hostile work environment claim under Title VII of the Civil Rights Act of 1964 Initially, the court dismissed plaintiff’s complaint, and provided plaintiff with an opportunity to amend her…

Read More Hostile Work Environment Claim Dismissed; Single Remark Insufficiently “Severe”
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From Basora-Jacobs v. Palevsky, 2020 WL 3868710 (E.D.N.Y. July 9, 2020): [Plaintiff’s] complaint does not state sufficient facts to support a Title VII claim against Plaintiff’s employer. “A plaintiff asserting a Title VII discrimination claim must allege facts showing that “(1) the employer took adverse action against h[er] and (2) h[er] race, color, religion, sex…

Read More Title VII Discrimination Complaint Dismissed; No Facts Alleged to Suggest That Termination or Retaliation Was Done For Discriminatory Reason
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In Mauro v. New York City Department of Education et al, 2020 WL 3869206 (S.D.N.Y. July 9, 2020), the court, inter alia, adopted a Magistrate Judge’s Report and Recommendation dismissing plaintiff’s hostile work environment claim asserted against the New York City Department of Education under Title VII of the Civil Rights Act of 1964, the…

Read More Race-Based Hostile Work Environment Claim Against NYC Department of Education Dismissed; “Not a Good Fit” Comment Notwithstanding
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In Zoll v. Northwell Health, Inc., 19-2716, 2020 WL 3493498 (2d Cir. June 29, 2020), the Second Circuit affirmed the district court’s dismissal, on summary judgment, of plaintiff’s race discrimination claim asserted under Title VII of the Civil Rights Act of 1964. Plaintiff, who is white, asserted that she suffered two adverse actions on the…

Read More 2d Circuit Affirms Dismissal of White Plaintiff’s Title VII Race Discrimination Claim
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In Calvelos v. City of New York et al, 2020 WL 3414886 (S.D.N.Y. June 22, 2020), the court, inter alia, held that plaintiff stated a race-based hostile work environment claim under Title VII of the Civil Rights Act of 1964. From the decision: Plaintiff alleges that, during his first eight months at West Facility, Warden…

Read More Title VII Race-Based Hostile Work Environment Claim Sufficiently Alleged Against City of New York
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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 Morales v. Triborough Podiatry, P.C., No. 2019-03110, 521586/18, 2020 N.Y. Slip Op. 03408, 2020 WL 3261059 (N.Y.A.D. 2 Dept. June 17, 2020), the Second Department reversed the lower court’s order denying defendant’s motion to dismiss plaintiff’s complaint alleging race and sex discrimination under the New York City Human Rights Law. From the decision: The…

Read More Discrimination Complaint Should Have Been Dismissed; Employment Refusal Preceded Communication of Employment Decision
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Today is Juneteenth, which celebrates the ending of slavery in the United States. On this day in 1865, Union soldiers landed at Galveston, Texas with news that the Civil War had ended that enslaved persons were now free. This was, notably, two years after the Emancipation Proclamation (which became official on January 1, 1863). Juneteenth…

Read More Juneteenth: 2020
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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 Sanderson v. Leg Apparel et al, 2020 WL 3100256 (SDNY June 11, 2020), the court, inter alia, held that plaintiff sufficiently alleged his race-based discrimination claim under Title VII of the Civil Rights Act of 1964, the New York State Human Rights Law, and the New York City Human Rights Law. From the decision:…

Read More Race Discrimination Claims Sufficiently Alleged; Allegations Included Disproportionately Heavy Workload
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