Court: S.D. Ohio – Pospis Law, PLLC

September 10, 2025 by mjpospis

Pregnancy/Lactation-Related Hostile Work Environment Claims Survive Dismissal

In Varney v. Health Carousel, LLC, Case No. 1:24-cv-624, 2025 WL 2605783 (S.D.Ohio Sept. 9, 2025), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s pregnancy/lactation-related hostile work environment constructive discharge claim asserted under Title VII of the Civil Rights Act of 1964. This decision underscores that, when evaluating hostile work environment claims, it…

Race-Based Hostile Work Environment Claim Dismissed; Alleged Events, While “Troubling,” Were Too Remote

In Nash v. City of Cincinnati et al, 2025 WL 2403821 (S.D.Ohio Aug. 19, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s race-based hostile work environment claim. From the decision: Defendants next move to dismiss Plaintiff’s hostile work environment claim. (Motion, Doc. 4, Pg. ID 42.) Title VII protects an employee who…

Sexual Harassment Complaint Dismissal Recommended; Invitations Did Not Amount to “Unwelcome” Conduct Comprising “Sexual Advances or Favors”

In Wolfe v. Carter’s, Inc., 19-cv-560, 2021 WL 3562911 (S.D. Ohio Aug. 11, 2021), the court recommended the dismissal of plaintiff’s “quid pro quo” and “hostile work environment” sexual harassment claims asserted under Title VII of the Civil Rights Act of 1964. This case is instructive regarding, for example, the circumstances under which “requests for…