Sexual Harassment

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In Frehoo, Inc. v. Bureau of Labor and Industries, 510 P.3d 888, 901, 319 Or. App. 548 (Or. App. May 18, 2022), the Court of Appeals of Oregon held that the evidence supported the conclusion by Oregon’s Bureau of Labor and Industries (BOLI) that an adult-entertainment establishment subjected an underage dancer to hostile work environment…

Read More Underage Exotic Dancer & Trafficking Victim Was Subject to Sexual Harassment, Court Holds
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In Gray v. Koch Foods, Inc. et al, 2022 WL 141533 (M.D.Ala. Jan. 14, 2022), the court, inter alia, denied defendants’ motion for summary judgment on plaintiff’s claim of hostile work environment sexual harassment asserted under Title VII of the Civil Rights Act of 1964. From the decision: The facts at issue here do not…

Read More Sexual Harassment Claim Survives Summary Judgment; Conduct Was Sufficiently “Severe” Even if Not “Pervasive”
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In Delagrange v. Weaver Popcorn Manufacturing, Inc., 1:20-CV-451-HAB, 2022 WL 3081978 (N.D.Ind. Aug. 3, 2022), the court, inter alia, dismissed plaintiff’s same-sex sexual harassment claim asserted under Title VII of the Civil Rights Act of 1964. The court summarized the black-letter law on this issue, arising from U.S. Supreme Court precedent, as follows: Same-sex harassment…

Read More Same-Sex Sexual Harassment Claim Dismissed
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In Karamatic v. Peyton Resource Group, L.P., No. 3:21-CV-02304-N, 2022 WL 2972222 (N.D.Tex. July 26, 2022), the court, inter alia, held that plaintiff sufficiently alleged hostile work environment sexual harassment in violation of Title VII of the Civil Rights Act of 1964. In concluding that plaintiff’s complaint adequately alleged actionable sexual harassment, the court explained:…

Read More Sexual Harassment Hostile Work Environment Claim Sufficiently Alleged, Holds Texas Court
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In Mellett v. City of Philadelphia, No. 20-cv-1629-JMY, 2022 WL 2391141 (E.D.Pa. July 1, 2022), the court, inter alia, denied defendant’s motion for summary judgment as to plaintiff’s retaliation claim. From the decision: Plaintiff has brought forth evidence that Defendant’s alleged retaliatory conduct occurred within days of her complaining about Lieutenant Frank’s conduct and that…

Read More Retaliation Claim, Arising From “Antagonism” Following Complaints of Sexual Harassment, Survives Summary Judgment
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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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