Employment Discrimination

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In Farmer v. Mizuho Securities USA LLC, No. 151348/2024, 2025 WL 1786172 (N.Y. Sup Ct, New York County June 25, 2025), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s allegations of retaliation under the New York State and City Human Rights Laws. From the decision: Plaintiff alleged that in early December 2020 and…

Read More Retaliation Claims Survive Dismissal, Allegations Included Acceptance of “Resignation” Following Complaints of “Sexist Attitude” Under NYS and NYC Human Rights Laws
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In Shinn v. Pennsylvania School Boards Association, CIVIL NO. 1:23-cv-02097, 2025 WL 1839494 (M.D.Pa. July 3, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s claim of hostile work environment sexual harassment asserted under Title VII of the Civil Rights Act of 1964. From the decision: Here, Shinn’s alleged workplace harassment was neither…

Read More Title VII Hostile Work Environment Sexual Harassment Claim Dismissed; Leave to Amend Complaint Granted
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In Williams v. NYC DSS-HRA, No. 101114/2024, 2025 WL 1810234 (N.Y. Sup Ct, New York County July 01, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s age-based hostile work environment claim under the New York City Human Rights Law. From the decision: Plaintiffs also attempt to plead a hostile work environment under…

Read More Hostile Work Environment Claim Dismissed; Allegations Evidenced “Workplace Frustration ” and “Inter-Personal Issues”
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In Esqueda, M.D., Jonathan v. NYU Langone Hospitals, 2025 WL 1785870 (SDNY June 27, 2025), the court, inter alia, granted defendants’ motion for summary judgment on plaintiff’s race- and national origin-based hostile work environment claims asserted under Title VII of the Civil Rights Act and 42 U.S.C. § 1981. After summarizing the black-letter law applicable…

Read More Race, National Origin-Based Hostile Work Environment Claims Dismissed; Alleged Mocking of Accent Insufficient
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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 Simmons v. Baccarat Inc., No. 651516/2023, 2025 WL 1735659 (N.Y. Sup Ct, New York County June 23, 2025), the court, inter alia, granted plaintiff’s motion to dismiss plaintiff’s claims of hostile work environment and sexual harassment under the New York State and City Human Rights Laws. From the decision: The Moving Defendants correctly assert…

Read More Hostile Work Environment, Sexual Harassment Claims Dismissed; Evidence Indicated That Plaintiff Participated in “Sexually Themed” Text Messages
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In Kapllanaj v. Healthfirst PHSP, Inc., No. 152720/2021, 2025 WL 1707852 (N.Y. Sup Ct, New York County June 17, 2025), the court, inter alia, denied defendants’ motion for summary judgment on plaintiff’s retaliation claims asserted under the New York State and City Human Rights Laws. From the decision: The branch of the motion for summary…

Read More Retaliation Claims Against Healthfirst Survive Summary Judgment
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In Samuel v. Institute for Community Living, Inc., No. 150885/2024, 2025 WL 1180332 (N.Y. Sup Ct, New York County Apr. 22, 2025), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s employment discrimination, hostile work environment, and retaliation claims. The court summarized the facts as follows: Plaintiff alleges she always performed her work satisfactorily…

Read More Age Discrimination, Hostile Work Environment, Retaliation Claims Survive Dismissal; Allegations Include “Old Bitch”, “Fat Loser”, and “Piece of Crap” Comments
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In Owens v. PriceWaterHouseCoopers LLC, 1:24-cv-5517-GHW, 2025 WL 1677001 (S.D.N.Y. June 12, 2025), the court clarified the standard for “sexual harassment” claims asserted under the New York City Human Rights Law. The court explained: The question, accordingly, becomes how to define the subset of discriminatory conduct that is also “sexual harassment.” As stated above, the…

Read More “Sexual Harassment” under the NYCHRL Need Not Be “Lewd or Sexual”; Motion to Compel Arbitration Denied
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In Rivera v. Target Corp., 24-CV-6965 (JPO), 2025 WL 1616863 (S.D.N.Y. June 6, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s Americans with Disabilities Act (ADA) discrimination claim, due to the failure to meet the “administrative exhaustion” requirement. From the decision: Rivera’s allegations before the EEOC made no reference to disability discrimination,…

Read More ADA Disability Discrimination Claim Dismissed Due to Failure to Exhaust Administrative Remedies
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