42 USC § 1981

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In Brown v. Valvoline, LLC et al, 2024 WL 2946099 (S.D.Tex. June 11, 2024), the court, inter alia, granted defendants’ motion for summary judgment on plaintiff’s claims of race-based hostile work environment asserted under Title VII of the Civil Rights Act of 1964 and § 1981. From the decision: The facts presented to the Court…

Read More N-Word, “Knuckle Heads” Comments Did Not Give Rise to Actionable Hostile Work Environment, Court Holds
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In Thompson v. Shutterstock, Inc. et al, 23-CV-4155 (JGLC), 2024 WL 2943813 (S.D.N.Y. June 10, 2024), the court, inter alia, denied defendant Shutterstock’s motion to dismiss plaintiff’s claim of retaliation asserted under 42 USC § 1981. Here, plaintiff based his retaliation claim on comments alleged to have been made by Shutterstock’s chief HR officer (Garfield)…

Read More Retaliation Claim, Under 42 USC § 1981, Sufficiently Alleged Against Shutterstock
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In Trotter v. National Football League, 23-cv-8055 (JSR), 2024 WL 2952637 (S.D.N.Y. June 12, 2024), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s claim of retaliation asserted under 42 USC § 1981. From the decision: The sufficiency of Trotter’s retaliation claim turns on whether he has adequately alleged that he engaged in some protected…

Read More Retaliation Claim Sufficiently Alleged Against NFL, Court Finds
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In Anderson, Keesha v. Amazon.com, Inc. et al, 23-cv-8347, 2024 WL 2801986 (S.D.N.Y. May 31, 2024), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s claim of race discrimination asserted under 42 U.S.C. § 1981. This decision discusses and applies the impact of the Supreme Court’s recent decision in Muldrow v. City of St.…

Read More Race Discrimination Claim Against Amazon Sufficiently Alleged; Court Considers Impact of SCOTUS Muldrow Decision on Section 1981 Claims
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In Anderson, Keesha v. Amazon.com, Inc. et al, 23-cv-8347, 2024 WL 2801986 (S.D.N.Y. May 31, 2024), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s claims of race discrimination/hostile work environment under the New York State and City Human Rights Laws. From the decision: The NYCHRL does not distinguish between claims of ‘discrimination’ and…

Read More Race Discrimination Claims Sufficiently Alleged Against Amazon, Court Finds
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In Johnson v. School District of Philadelphia, 2024 WL 1773358 (E.D.Pa. April 24, 2024), 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 and 42 U.S.C. § 1981. From the decision: For racist comments, slurs, and jokes to…

Read More Hostile Work Environment Claims Dismissed; Comments Invoking “Racial Stereotypes” Did Not Amount to a “Steady Barrage”
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In Gordon-Mallett v. Mount Sinai Hospitals Group, Inc. et al, 22-cv-1159 (LJL), 2024 WL 1513910 (S.D.N.Y. April 8, 2024), the court, inter alia, denied defendants’ motion for summary judgment on plaintiff’s claims asserted under 42 U.S.C. § 1981, the New York State Human Rights Law, and the New York City Human Rights Law. As to…

Read More Sex, Race-Based Hostile Work Environment Claims Against Mt. Sinai Survive Summary Judgment
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In Floyd v. New York Public Radio, 23-cv-1096 (ALC), 2024 WL 1407058 (S.D.N.Y. April 2, 2024), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s claims of race discrimination asserted under 42 U.S.C. § 1981, the New York State Human Rights Law, and the New York City Human Rights Law. After summarizing the relevant…

Read More Radio Host Jami Floyd’s Race Discrimination Survives Motion to Dismiss
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In Goldberg v. Bespoke Real Estate LLC, et al, 23-CV-5614 (JPO), 2024 WL 1256006 (S.D.N.Y. March 25, 2024), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s claim of retaliation asserted under 42 U.S.C. § 1981. From the decision: The Goldberg Plaintiffs also assert a claim of unlawful retaliation under Section 1981 based on Goldberg’s opposition…

Read More Retaliation Claim Sufficiently Alleged; Communication of Discrimination Allegation Through Counsel Constituted “Protected Activity”
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In Goldberg v. Bespoke Real Estate LLC, et al, 23-CV-5614 (JPO), 2024 WL 1256006 (S.D.N.Y. March 25, 2024), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s race-based hostile work environment claim asserted under 42 U.S.C. § 1981. From the decision: The Goldberg Plaintiffs next bring a claim of hostile work environment under 42…

Read More Race-Based Hostile Work Environment Claim Survives Dismissal, Notwithstanding Plaintiff’s Alleged Use of Offensive Language
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