D Motion for Summary Judgment Denied (Hostile Work Environment)

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In Cagle v. Duro-Hilex Poly, LLC, No. 3:24-CV-154 (JCH), 2026 WL 628137 (D. Conn. Mar. 5, 2026), the court, inter alia, denied defendant’s motion for summary judgment on plaintiffs’ race- and color-based disparate treatment and hostile work environment under the Connecticut Fair Employment Practices Act. (Note: I am not admitted to practice law in Connecticut;…

Read More Race/Color Based Disparate Treatment and Hostile Work Environment Claims Survive Summary Judgment
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In Melton v. I-10 Truck Ctr. Inc., No. 23-14175, 2026 WL 319183 (11th Cir. Feb. 6, 2026), the U.S. Court of Appeals for the 11th Circuit vacated the lower court’s decision awarding defendant summary judgment on plaintiff’s claim of a racially hostile work environment under 42 U.S.C. § 1981. From the decision: To prevail on…

Read More Racially Hostile Work Environment Claim Resurrected From Summary Judgment Dismissal; Evidence Included Use of Racial Slur “Boy”
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In Loiseau et al v. Bozzuto’s Inc. et al, No. CV 3:22-CV-01485 (JCH), 2025 WL 3295434 (D. Conn. Nov. 25, 2025), the court, inter alia, denied defendants’ motion for summary judgment on plaintiffs’ race-based hostile work environment claims. The court summarized the black-letter law as follows: To prevail on a hostile work environment claim under…

Read More Race-Based Hostile Work Environment Claims Survive Summary Judgment
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In Cain v. United Mortgage Corp. and Emmanuel Catechis, 21-cv-3325 (BMC), 2025 WL 2932758 (E.D.N.Y. Oct. 15, 2025), the court, inter alia, denied defendants’ motion for summary judgment on plaintiff’s race-based hostile work environment claims asserted under Title VII of the Civil Rights Act of 1964, the New York State Human Rights Law, and the…

Read More Racially Hostile Work Environment, Based on “N—-r” Nickname, Survives Summary Judgment
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In Schwengel v. Cave Enterprises Operations, LLC d/b/a Burger King of Saukville, 24-cv-558-wmc, 2025 WL 2898381 (W.D.Wis. Oct. 10, 2025), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s hostile work environment sexual harassment claim asserted under Title VII of the Civil Rights Act of 1964. The court summarized, and applied, the…

Read More Title VII Hostile Work Environment Sexual Harassment Claim Survives Summary Judgment; Court Cites Alleged Physically Threatening Behavior and Explicit Sexual Comments
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In Boodoo v. AMP Home Care LLC, Civil Action No. 24-1056, 2025 WL 2840801 (W.D.Pa. Oct. 7, 2025), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s hostile work environment sexual harassment claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: Defendant maintains that Plaintiff has…

Read More Title VII Sexual Harassment Claim Survives Summary Judgment; Evidence Included That Alleged Harasser Stated to Plaintiff “I Want to Fuck You”
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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 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 Hechavarria v. Scorch Bar & Grill Inc., 23-CV-1743 (NGG) (VMS), 2025 WL 2476346 (E.D.N.Y. Aug. 28, 2025), the U.S. District Court for the Eastern District of New York, inter alia, denied defendants’ motion for summary judgment on plaintiff’s race-based hostile work environment claims. Plaintiff contends, among other things, that he was engaged in an…

Read More One-Time N-Word Use Sufficient to Defeat Summary Judgment on Race-Based Hostile Work Environment Claims, EDNY Holds
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In Choudhury v. Northwell Health, Inc., 23-cv-01406 (NCM) (SIL), 2025 WL 2300220 (E.D.N.Y. Aug. 8, 2025), the court, inter alia, denied defendants’ motion for summary judgment on plaintiff’s claims of race, religion, and national origin based hostile work environment asserted under the New York State Human Rights Law. Notably, the court initially granted defendants’ motion…

Read More Hostile Work Environment Claims Survive Summary Judgment Under NYS Human Rights Law (But Not Title VII)
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