Court: SDNY

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In Lindsey v. Citigroup Global Markets Inc., 1:23-cv-10166-ALC, 2025 WL 2781281 (S.D.N.Y. Sept. 30, 2025), the court discussed and applied the “continuing violation” doctrine under Title VII of the Civil Rights Act of 1964. In sum, plaintiff alleges that she was subjected to a hostile work environment, commencing in 2007 with an alleged sexual assault,…

Read More Title VII Hostile Work Environment Claim Survives Motion to Dismiss; Applicability of “Continuing Violation” Doctrine Must Await Further Factual Development
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In Smith v. Meta Platforms, Inc., 24 Civ. 4633 (JPC), 2025 WL 2782484 (S.D.N.Y. Sept. 30, 2025), the court held that a party invoking the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 (EFAA) must actually allege facts that constitute sexual harassment. Here, the plaintiff did not: To determine whether this…

Read More Non-Sexual Gender Discrimination Did Not Trigger EFAA’s Arbitration Bar
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In Mehta, Anisha v. DLA Piper LLP, 23 Civ. 4757 (AT), 2025 WL 2771659 (S.D.N.Y. Sept. 29, 2025), the court denied defendant’s motion for summary judgment on plaintiff’s claims of pregnancy discrimination asserted under Title VII of the Civil Rights Act of 1964, the New York State Human Rights Law, and the New York City…

Read More Pregnancy Discrimination Claims Survive Summary Judgment Against DLA Pipler
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In Carey v. NYS Department of Health, 2025 WL 2732918 (S.D.N.Y. Sept. 25, 2025), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s sex-based hostile work environment claims asserted under the New York State and City Human Rights Laws. This decision illustrates the difference between the relatively restrictive federal law, on the…

Read More Sex-Based Hostile Work Environment Claims Survive Under New York State and City Human Rights Laws
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In Kelly v. Rosenberg & Estis, P.C. et al, 25-cv-4776 (CM), 2025 WL 2709157 (S.D.N.Y. Sept. 23, 2025), the court, inter alia, held that the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021  (EFAA) applied to plaintiff’s entire case – which included her allegations of sexual harassment – and thus denied…

Read More Sexual Harassment Claim Made Out Under NYCHRL; EFAA Applied to Entire Case; Motion to Compel Arbitration Denied
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In Pullman et al v. Collins et al, No. 24-CV-1383 (KMK), 2025 WL 2673807 (S.D.N.Y. Sept. 18, 2025), the court, inter alia, denied defendants’ motion to dismiss a plaintiff’s claim of hostile work environment sexual harassment asserted under the New York State Human Rights Law. From the decision: Next, Defendants argue that Dinsmore has failed…

Read More Sexual Harassment Claim Sufficiently Alleged Under Recently-Amended NYS Human Rights Law, Court Holds
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In Delgado v. Donald Trump for President, Inc., Sean Spicer, Reince Priebus, Stephen Bannon, 19 Civ. 11764 (AT), 2025 WL 2636259 (S.D.N.Y. Sept. 11, 2025), the court, inter alia, denied defendants’ motion for summary judgment on plaintiff’s pregnancy discrimination claims asserted under the New York State Human Rights Law (NYSHRL) and the New York City…

Read More Pregnancy Discrimination Claims Against Trump Campaign Survive Summary Judgment
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In Colin S.K. Correa v. U.S. General Services Administration et al, 2025 WL 2532727 (S.D.N.Y. Sept. 2, 2025), the court, inter alia, dismissed plaintiff’s non-federal law discrimination claims. From the decision: Plaintiff cannot bring state law claims for employment discrimination under the New York City or New York State Human Rights Laws because Title VII…

Read More Court Dismisses Federal Employee’s NYS and NYC Human Rights Law Claims
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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 Udoh v. NYC Dept. of Probation, 24-cv-03982 (ER), 2025 WL 219961 (S.D.N.Y. Aug. 1, 2025), the court dismissed plaintiff’s sex discrimination claim asserted under Title VII of the Civil Rights Act of 1964, because plaintiff did not “administratively exhaust” that claim before the U.S. Equal Employment Opportunity Commission. From the decision: The Court finds…

Read More Court, Applying the “Administrative Exhaustion” Doctrine, Dismisses Title VII Sex Discrimination Claim
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