Employment Discrimination

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In Clarke v. SOC, LLC, No. 527239/24, 2025 WL 2614623 (N.Y. Sup Ct, Kings County Sep. 09, 2025), the court, inter alia, dismissed plaintiff’s claims under the New York State and City Human Rights Law, since the alleged conduct did not occur in New York. From the decision: Both the NYSHRL and NYCHRL make it…

Read More NYS and NYC Human Rights Law Discrimination Claims Dismissed; Geographic Requirement Not Satisfied
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In Cuellar v. Christie’s Inc., No. 155077/2023, 2025 WL 2429617 (N.Y. Sup Ct, New York County Aug. 21, 2025), the court, inter alia, granted defendants’ motion to dismiss plaintiff’s discrimination claims asserted under the New York State and City Human Rights Laws. The court summarized, and applied, the law as follows: A cause of action…

Read More Discrimination Claims Dismissed; In Context, “Lazy” Was Neutral & Not Used in a Racially-Derogatory Way
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In Santana v. Shook Hardy & Bacon, 2025 WL 2521193 (S.D.N.Y. Sept. 2, 2025), the court granted defendants’ motion to dismiss plaintiff’s discrimination, hostile work environment, and retaliation claims asserted under Title VII of the Civil Rights Act of 1964, the New York State Human Rights Law, and the New York City Human Rights Law.…

Read More Alleged Unprofessional Treatment Insufficient to State Claims for Discrimination, Hostile Work Environment and Retaliation
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In Williams v. Family Health International d/b/a FHI 360 et al, 2025 WL 2506580 (D.D.C. Sept. 2, 2025), the court, inter alia, held that plaintiff did not state a claim for hostile work environment under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 1981, and the District of Columbia Human Rights…

Read More Hostile Work Environment Claims Dismissed; Alleged Actions Were “Ordinary, Albeit Unpleasant”, Workplace Conduct
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In Fisher v. Valley Stream Central High School District et al, 2025 WL 2467046 (E.D.N.Y. Aug. 27, 2025), the court, inter alia, held that plaintiff sufficiently stated a cause of action for retaliation under Title VII of the Civil Rights Act of 1964. Specifically, plaintiff alleged that defendants suspended her pay and benefits, in retaliation…

Read More Title VII Retaliation Claim, Based on Complaints About Alleged Excessive Workload Due to Status as Unmarried Woman With Children, Survives Dismissal
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In Nazath v Our Lady of Consolation Nursing & Rehabilitative Care Center, No. 2023-06250, 615567/22, 2025 N.Y. Slip Op. 04796, 2025 WL 2458592 (App. Div. 2 Dept. Aug. 27, 2025), the Appellate Division, Second Department affirmed the lower court’s denial of defendant’s motion to dismiss plaintiff’s claims of disability discrimination and retaliation in violation of…

Read More Perceived-Disability Discrimination & Retaliation Claims Survive Dismissal, 2nd Dept. Holds
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In a recent case, In re AAM Holding Corp., 2025 WL 2433651 (2d Cir. Aug. 25, 2025), the U.S. Court of Appeals for the Second Circuit weighed in on an important aspect of federal anti-discrimination law, namely, the authority of the U.S. Equal Employment Opportunity Commission (EEOC) to continue its investigation – here, its quest…

Read More 2nd Circuit: EEOC Retains Investigative Authority Following Right-to-Sue Letter
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In Rachwalski v. Pamela Bondi et al, 2025 WL 2432162 (S.D.Ind. Aug. 21, 2025), the court, inter alia, granted defendants’ motion for summary judgment on plaintiff’s sex-based hostile work environment claim asserted under Title VII of the Civil Right Act of 1964. From the decision: Title VII prohibits employers from discriminating against employees based on…

Read More Sex-Based Hostile Work Environment Claim Dismissed; Alleged Conduct Was Not Objectively Offensive Nor Severe or Pervasive
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In Yelder v. Hegseth, 2025 WL 2373355 (8th Cir. 2025), the court, inter alia, affirmed the summary judgment dismissal of plaintiff’s hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: Here, Yelder argues that the following conduct constitutes severe or pervasive conduct: (1) Parker ripping up…

Read More Title VII Hostile Work Environment Claim, Though Based on Insensitive and Offensive Comments, Held Properly Dismissed
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