Sexual Harassment

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In Karpaitis v. Mandal’s, Inc., 21-cv-305, 2022 WL 2445004 (S.D. Miss. July 5, 2022), the court, inter alia, dismissed plaintiff’s quid pro quo sexual harassment claim. From the decision: [A] quid pro quo sexual harassment claim requires that the plaintiff suffer a tangible employment action for her refusal to submit to a supervisor’s sexual demands. Ellerth,…

Read More “Quid Pro Quo” Sexual Harassment Claim Dismissed, Notwithstanding “Flirtatious, Offensive, and Altogether Inappropriate” Comments
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In Karpaitis v. Mandal’s, Inc., 21-cv-305, 2022 WL 2445004 (S.D. Miss. July 5, 2022), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s retaliation claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: Plaintiff also alleges that she was terminated for engaging in the protected activity of reporting…

Read More Retaliation Claim, Arising From Sexual Harassment Report, Survives Dismissal
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In Del Villar v. Hyatt Hotel Corporation et al., 19-CV-10891 (JMF), 2022 WL 2316205 (S.D.N.Y. June 28, 2022), the court granted Hyatt’s motion for summary judgment on plaintiff’s claim of hostile work environment sexual harassment under Title VII of the Civil Rights Act of 1964, the New York State Human Rights Law, and the New…

Read More Hostile Work Environment Sexual Harassment Claim Dismissed Against Hyatt Hotel Corporation
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In Morales v. Supreme Maintenance Inc. et al, No. 1:21-cv-01044-KWR-JHR, 2022 WL 2290605 (D.N.M. June 24, 2022), the court denied defendant’s motion to dismiss plaintiff’s sexual harassment and retaliation claims. As to plaintiff’s retaliation claim, the court explained: Here, Plaintiff alleges that she engaged in protected activity by opposing sexual harassment by an employee at…

Read More Sexual Harassment, Retaliation Claims Survive Dismissal; Complaint Alleged Harassment by Non-Employee
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In Louis v. Window Rock Unified School District, No. CV-20-08193-PCT-DJH, 2022 WL 2132239 (D.Ariz. June 14, 2022), the court, inter alia, dismissed plaintiff’s claim of hostile work environment sexual harassment asserted under Title VII of the Civil Rights Act of 1964. Plaintiff’s claims arose from text messages exchanged between her and a non-party (the School…

Read More Text Message-Based Hostile Work Environment Sexual Harassment Claim Dismissed
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In Henry v. Ground, No. 153458/2021, 2022 WL 2158368 (N.Y. Sup Ct, New York County June 10, 2022), the court, inter alia, dismissed plaintiff’s hostile work environment sexual harassment claim asserted under the New York State and City Human Rights Laws. Plaintiff bases her claim on two incidents (one in July 2018, the other in…

Read More Hostile Work Environment Sexual Harassment Claim, Based on Off-Premises Conduct by Co-Workers, Dismissed
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In Kirstyn Crawford v. American Broadcasting Co., Inc., No. 157874/2021, 2022 WL 2066925 (N.Y. Sup Ct, New York County June 08, 2022), the court granted individual defendant Michael Corn’s motion to dismiss plaintiff’s hostile work environment sexual harassment claims, asserted under the New York State and City Human Rights Laws, as time-barred. Plaintiff (an ABC…

Read More Hostile Work Environment Sexual Harassment Claims Dismissed, as Time-Barred, Against Former ABC Producer Michael Corn
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In Doe v. Louis Leonelli et al, brought under the New York City Victims of Gender-Motivated Violence Act, NYC Administrative Code § 10-1105, the court denied plaintiff’s (unopposed) motion to proceed pseudonymously. The court stated the applicable black-letter law as follows: Rule 10(a) of the Federal Rules of Civil Procedure provides that the “title of…

Read More Plaintiff May Not Proceed Pseudonymously in Priest Sex Abuse Case
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In Pachura v. Lloyd J. Austin, III, Secretary, Department of Defense, 6:21-CV-0316 (LEK/ATB), 2022 WL 1909546 (N.D.N.Y. June 3, 2022), the court denied defendant’s motion to dismiss plaintiff’s hostile work environment sexual harassment claim asserted under Title VII of the Civil Rights Act of 1964. The court summarized plaintiff’s allegations, in sum, as follows: Between…

Read More Sexual Harassment Claim Survives Dismissal; Allegations Included Harassment by Facebook Messenger
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In Rodriguez v. Town of Cicero et al, No. 20 C 7608, 2022 WL 1773715 (N.D.Ill. June 1, 2022), the court, inter alia, held that plaintiff sufficiently alleged a hostile work environment sexual harassment claim under Title VII of the Civil Rights Act of 1964. The court summarized plaintiff’s sexual harassment allegations as follows: The…

Read More Police Officer’s Title VII Hostile Work Environment Sexual Harassment Claim Sufficiently Alleged, Court Holds
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