Sexual Harassment

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In Tardiff v. Laborers International Union of North American Local Union 609 et al, 2025 WL 2374000 (D.Mass. Aug. 15, 2025), the court, inter alia, held that plaintiff sufficiently alleged sexual harassment under Massachusetts state law and Title VII of the Civil Rights Act of 1964. From the decision: Ms. Tardiff has alleged that Mr.…

Read More Hostile Work Environment Sexual Harassment Claims Survive Dismissal; Allegations Include Disparaging Comments and Brandishing Firearm
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In Erazo v. IGH Restoration LLC, 23 Civ. 3982 (DEH), 2025 WL 2298712 (S.D.N.Y. Aug. 8, 2025), concerning alleged sexual harassment, the court denied defendants’ motion for summary judgment on plaintiff’s claims under Title VII of the Civil Rights Act of 1964. Specifically, this decision discusses the issue of whether a defendant is considered an…

Read More Sexual Harassment Plaintiff Presents Sufficient Evidence to Create Triable Issue as to Whether Defendant is a Title VII “Employer”
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In Lambert et al v. New Start Capital LLC et al, 1:24-cv-8055-GHW, 2025 WL 2295254 (S.D.N.Y. August 7, 2025), the court addressed a novel legal questions regarding the relatively new Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act (EFAA). In sum, one plaintiff – Lambert, a Black woman – alleges that she was…

Read More SDNY Interprets the EFAA to Apply to Sexual Harassment & Related Wage-and-Hour Claims, But Not to Third Plaintiff’s Claims Unrelated to Sexual Harassment Claims
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In Mofrad v. United Parcel Service, Inc., Case No. 23-cv-01899-AMO, 2025 WL 2308492 (N.D.Cal. Aug. 11, 2025), the court denied defendant’s motion for summary judgment on plaintiff’s claim of sexual harassment under California’s Fair Employment and Housing Act (“FEHA”). This decision is interesting, in that it arises from a scenario involving allegations by a male…

Read More Sexual Harassment Claim, Arising From Alleged Harassment of Male by Female Subordinate, Survives Summary Judgment
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In Pacheco v. Kukaj, No. 158029/2024, 2025 WL 2256864 (N.Y. Sup Ct, New York County Aug. 05, 2025), the court denied defendant’s motion to dismiss plaintiff’s cause of action asserted under Victims of Violent Crime Protection Act, N.Y.C. Administrative Code § 10-401 et seq. From the decision: Under CPLR § 3211(a)(7), a “party may move…

Read More Plaintiff Sufficiently Alleges Claim Under NYC’s Victims of Violent Crime Protection Act, Court Holds
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In Parks v. Nordson Medical of NH Inc., 2025 WL 2177177 (E.D.Tenn. July 31, 2025), the court held that plaintiff’s allegations did not plausibly state a claim for sexual harassment, and therefore that the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 did not apply. From the decision: A court determines…

Read More Sexual Harassment Insufficiently Alleged; “Vulgar” Conduct Not Actionable
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In Thomas v. Poo Bah Enterprises, Inc., d/b/a Rick’s Cabaret Chicago, No. 25-cv-77, 2025 WL 2084159 (N.D.Ill. July 24, 2025), the court explained and clarified the pleading standard is contemplated by the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 in the context of a sexual harassment dispute. Here, plaintiff –…

Read More Court Adopts NY Federal Court’s Interpretation of EFAA in Retaliation/Sexual Harassment Case
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In Hicks v. CEC Entertainment Holdings I, Inc., 2025 WL 1770787 (D.Del. June 26, 2025), the court denied defendant’s motion to dismiss plaintiff’s retaliation claim, premised on the plaintiff’s termination following her complaint about alleged wrongful activities by her immediate supervisor, including sexual harassment of female employees. Specifically, the court held that plaintiff’s claims fell…

Read More Retaliation Claim, Arising From Termination Following Complaint of Sexual Harassment, Survives Dismissal; EFAA Applied
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In Breiding v. High Hopes Films, LLC, No. 152385/2023, 2025 WL 1994466 (N.Y. Sup Ct, New York County July 16, 2025), the court, inter alia, denied defendants’ motion for summary judgment on plaintiff’s claims of hostile work environment, sexual harassment, and gender discrimination claims asserted under the New York State and City Human Rights Laws.…

Read More Hostile Work Environment, Sexual Harassment, Discrimination Claims Survive Summary Judgment
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In Spann v. FedEx Freight, Inc., 2025 WL 1938355 (5th Cir. July 15, 2025), the U.S. Court of Appeals for the Fifth Circuit, inter alia, affirmed the lower court’s grant of summary judgment on plaintiff’s race- and gender-based hostile work environment claims. From the decision: A hostile work environment claim is composed of a series…

Read More Race, Gender Hostile Work Environment Claims Properly Dismissed: Fifth Circuit
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