Court: U.S. Court of Appeals 2nd Circuit

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In Nambiar v. Cent. Orthopedic Grp., LLP, No. 24-1103, 2025 WL 3007285 (2d Cir. Oct. 28, 2025), the U.S. Court of Appeals for the Second Circuit – applying the “stray remarks” doctrine – affirmed the lower court’s award of summary judgment dismissing plaintiff’s claim of sex-based discrimination. From the decision: Nambiar points to remarks made…

Read More Sex Discrimination Claims Properly Dismissed; Alleged Discriminatory Comments Were “Stray Remarks”
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In Brown v. Montefiore Health System, Inc., No. 24-3078-cv, 2025 WL 2985389 (2d Cir. Oct. 23, 2025), the U.S. Court of Appeals for the Second Circuit held that plaintiff indeed stated a claim for a race-based discrimination (termination) claim under Title VII of the Civil Rights Act of 1964 and the New York State Human…

Read More 2nd Circuit Vacates Lower Court Decision; Race-Based Termination Claim Survives Dismissal
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In Tillman . Grenadier Realty Corp., GRC Management, 2025 WL 2910611 (2d Cir. 2025), the U.S. Court of Appeals for the Second Circuit affirmed the lower court’s award of summary judgment to defendant on plaintiff’s claim of age discrimination under the Age Discrimination in Employment Act (ADEA). From the decision: On appeal, Tillman argues that…

Read More Age Discrimination Claim Properly Dismissed; Financial Hardship Not Pretext for Termination
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In Pizarro v. Quezada et al, No. 24-2422, 2025 WL 2865251 (2d Cir. Oct. 9, 2025) (Summary Order), the U.S. Court of Appeals for the Second Circuit, inter alia, affirmed a lower court order denying defendants’ motion seeking remittitur of the jury’s award of $1.75 million in compensatory (emotional distress) damages. In sum, plaintiff alleged…

Read More 2nd Circuit Upholds $1.75 Million Emotional Distress Award to Sexual Harassment Plaintiff
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In Gehlaut v. New York City Department of Education, No. 24-1741 (2d Cir. 2025), the U.S. Court of Appeals for the Second Circuit affirmed the dismissal of plaintiff’s retaliation claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: To state a claim for retaliation under Title VII, “the plaintiff…

Read More Title VII Retaliation Claim Properly Dismissed; Temporal Proximity Not Shown
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In Chislett v. New York City Department of Education, No. 24-972-cv, 2025 WL 2725669 (2d Cir. Sept. 25, 2025), the U.S. Court of Appeals for the Second Circuit, inter alia, vacated the lower court’s award of summary judgment on plaintiff’s race-based hostile work environment claim. As it was undisputed that plaintiff subjectively perceived the environment…

Read More Race-Based Hostile Work Environment Claim Survives Summary Judgment Against the NYC Department of Education
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In Collins, Sam v. Federal Express Corporation, 2025 WL 1764809 (2d Cir. June 26, 2025), the U.S. Court of Appeals for the Second Circuit, inter alia, affirmed the lower court’s dismissal of plaintiff’s hostile work environment claims as being time-barred. From the decision: We also agree that Collins’ hostile-work-environment claims are time-barred. A hostile work…

Read More Hostile Work Environment Claims Against FedEx Properly Dismissed as Time-Barred, 2nd Circuit Holds
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In Flanagan et al v. Girl Scouts of Suffolk County, Inc. et al, 23-7900-cv, 2025 WL 1501751 (2d Cir. May 27, 2025), the court, inter alia, held that plaintiff plausibly alleged race discrimination under 42 U.S.C. § 1981 and the New York State Human Rights Law (NYSHRL), and vacated a lower court order holding otherwise.…

Read More Race Discrimination Claims Plausibly Alleged; 2nd Circuit Vacates Dismissal
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In Smart, Kathyann v. USA Labor for Hire, Inc., RC Global Energy Group, Inc., Oleg Tsimbler, No. 24-1791, 2025 WL 1217365 (2d Cir. April 28, 2025), the U.S. Court of Appeals for the Second Circuit, inter alia, affirmed the lower court’s denial of defendant’s motion for new trial or remittitur on plaintiff’s claims of hostile…

Read More 2nd Circuit Holds That Jury Properly Found Hostile Work Environment, Based on Racially Derogatory and Sexist Language,
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