Employment Discrimination Sufficiently Alleged

In Ajala v. Limani 51, LLC, No. 153433/2023, 2024 WL 5169823 (N.Y. Sup Ct, New York County Dec. 17, 2024), the court held that plaintiff sufficiently alleged a hostile work environment claims under the New York State and City Human Rights Laws. From the decision: A racially hostile work environment exists when the workplace is…

Read More Hostile Work Environment Claim Survives Dismissal; Court Cites Sex and Race-Based Comments
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In Jean-Pierre v. City of New York, No. 153859/2023, 2024 WL 4753498 (N.Y. Sup Ct, New York County Nov. 12, 2024), the court denied defendant’s motion to dismiss plaintiff’s claims of race discrimination and hostile work environment. From the decision: Plaintiff’s amended complaint alleges sufficient facts to support claims of discrimination and hostile work environment…

Read More Race-Based Discrimination & Hostile Work Environment Claims Sufficiently Alleged Against City of New York, Court Holds
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In Byrd v. Becerra, Civil Action No. 22-3746 (TSC), 2024 WL 4591438 (D.D.C. Oct. 28, 2024), the court, inter alia, held that plaintiff sufficiently alleged employment discrimination under Title VII of the Civil Rights Act of 1964. As to the “inference of discrimination” element, the court explained: Plaintiff has also pleaded an inference of discrimination…

Read More Title VII Race Discrimination Claim Survives Dismissal; Allegations Included Reassignment of Work to White Colleagues
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In McNellis v. Douglas Cnty. School District, 116 F.4th 1122 (10th Cir. Sept. 10, 2024), the court, inter alia, reversed the lower court’s dismissal of plaintiff’s religious discrimination claims asserted under Title VII of the Civil Rights Act of 1964 and the Colorado Anti-Discrimination Act. In sum, plaintiff, an assistant principal, was terminated following an…

Read More 10th Circuit Reverses Dismissal of Title VII Religious Discrimination Claim Arising From Comments Concerning “The Laramie Project” School Play
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In Sargent v. Amazon.com, Inc., Civil Action No. 23-1330-RGA, 2024 WL 3936490 (D.Del. Aug. 26, 2024), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s race-based hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: Plaintiff alleges he was subjected to a hostile work environment…

Read More Race-Based Hostile Work Environment Claim, Arising From Alleged Racist Graffiti, Survives Dismissal
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In Williams v. Breaking Ground Housing Development Fund Corporation et al, 22-cv-8715 (AS), 2024 WL 2882122 (S.D.N.Y. June 6, 2024), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s hostile work environment sexual harassment claim asserted under Title VII of the Civil Rights Act of 1964, the New York State Human Rights Law, and…

Read More Hostile Work Environment Sexual Harassment Claims, Based on Alleged Use of “Terms of Endearment”, Survive Dismissal
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In Moore, Kim v. Hadestown Broadway Limited Liability Company, No. 23-CV-4837 (LAP), 2024 WL 989843 (S.D.N.Y. March 7, 2024), the U.S. District Court for the Southern District of New York (in an opinion authored by Judge Preska), inter alia, denied defendant’s motion to dismiss plaintiff’s race-based hostile work environment claims. (I wrote about the court’s…

Read More Actress Plausibly Alleges Race-Based Hostile Work Environment Claims Under NYS and NYC Human Rights Laws (But Not Title VII)
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In Innes v. County of Warren et al, 1:22-cv-641 (BKS/TWD), 2024 WL 865864 (N.D.N.Y. Feb. 29, 2024), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s disability discrimination claims. As to plaintiff’s claims under the Americans with Disabilities Act (ADA), the court explained: Plaintiff alleges the following facts. Approximately an hour and a half…

Read More Disability Discrimination Claims Survive Dismissal; Court Cites Closeness in Time Between Hospitalization and Termination
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In Brown v. Cnty. of Westchester, 22-CV-06146 (PMH), 2024 WL 21937 (S.D.N.Y. Jan. 2, 2024), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s claims of race discrimination, sex/gender discrimination, and hostile work environment (but only as to timely conduct). From the decision: To establish a prima facie case of discrimination under Title VII…

Read More Title VII Race Discrimination Claim Survives Dismissal; Sexual Harassment Claim Dismissed as Time-Barred
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