Employment Discrimination

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In Dorio v. Cmty. Hous. Mgmt. Corp. et al, No. 62784/2025, 2026 WL 90179 (N.Y. Sup. Ct. Jan. 8, 2026), the court, inter alia, granted defendants’ motion to dismiss plaintiff’s hostile work environment claim asserted under the New York State Human Rights Law. Among other things, plaintiff alleged that she was forced to endure a…

Read More Court Dismisses Scent-Based Hostile Work Environment Claim
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In Goldzweig v. Consolidated Edison Co. of New York, Inc., No. 25-0089-CV, 2026 WL 21005 (2d Cir. Jan. 5, 2026), the U.S. Court of Appeals for the Second Circuit, inter alia, affirmed the court’s award of summary judgment to defendant on plaintiff’s retaliation claims asserted under Title VII of the Civil Rights Act of 1964,…

Read More 2nd Circuit Vacates Summary Judgment Dismissal of NYC Human Rights Law Retaliation Claim
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In Alexander v. New York City Health and Hosp. Corp., No. 156315/2020, 2025 WL 3708596 (N.Y. Sup. Ct. Dec. 17, 2025) – a case involving allegations of sex and gender discrimination, sexual harassment, hostile work environment, constructive discharge, and retaliation – the court, inter alia, granted defendants’ motion to compel discovery responses from plaintiff. The…

Read More Court Explains Discovery Obligations in Sexual Harassment Case
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In O’Connor v. Citigroup Global Markets, Inc., No. 158198/2024, 2025 WL 3709253 (N.Y. Sup. Ct. Dec. 17, 2025), the court, inter alia, held that plaintiff failed to state a claim of sex discrimination under the New York City Human Rights Law. After determining that plaintiff not receiving a promotion constituted an “adverse employment action,” it…

Read More Sex Discrimination Claims Against Citigroup Dismissed
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In Ibrahim v. Marco A. Rubio, No. 1:24-CV-02915 (TNM), 2025 WL 3718637 (D.D.C. Dec. 23, 2025), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s age discrimination claim asserted under the Age Discrimination in Employment Act (ADEA). From the decision: Ibrahim states a plausible ADEA claim. He is 65 years old. Compl. ¶ 47.…

Read More U.S. Embassy Employee Plausibly Alleges ADEA Age Discrimination Claim, Court Holds
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In Marlin v. Daniel P. Driscoll, Secy’ of the Army, No. 1:21-CV-00989 (CJN), 2025 WL 3640628 (D.D.C. Dec. 16, 2025), the court, inter alia, granted defendant’s motion for summary judgment dismissing plaintiff’s disability-based hostile work environment claim. From the decision: Marlin argues that she was “subjected to a hostile work environment from at least 2012…

Read More Disability-Based Hostile Work Environment Claim Dismissed; Alleged Conduct Over Several Years Insufficient
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In Quinn v. Austin, No. CV 24-10285-NMG, 2025 WL 2841890 (D. Mass. Oct. 7, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: In support of a hostile work environment claim in this case, Quinn…

Read More Hostile Work Environment Claim Dismissed, Notwithstanding Confederate Flag Allegation
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In Croswell v. 7 Rising Star Inc., No. 520808/2024, 2025 WL 3634069 (N.Y. Sup. Ct. Dec. 09, 2025), the court found defendants liable, and awarded plaintiff substantial damages, for her claim of sexual harassment under the New York City Human Rights Law. The court summarized the law, and applied it to the facts, as follows:…

Read More Sexual Harassment Plaintiff Awarded Damages, Following Inquest
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In Boliak v. Father Michael P. Reilly et al, No. 153941/16, 2025 WL 3672342 (N.Y. App. Div. 1 Dept. Dec. 18, 2025), the court, inter alia, held that the lower court improperly dismissed plaintiff’s hostile work environment claims under the “ministerial exception.” From the decision: Plaintiffs Boliak, Maureen Smith, and Thomas Rodes were all employed…

Read More Hostile Work Environment Claims Not Barred by the “Ministerial Exception”, First Department Holds
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In Sander v. Westchester Reform Temple, 2025 NY Slip Op 06958 (N.Y. Ct. Appeals Dec. 16, 2025), the New York Court of Appeals held that plaintiff’s discrimination claim was barred by the “ministerial exception.” From the decision: Plaintiff Jessie Sander alleges that she was fired from her teaching position at Westchester Reform Temple for co-authoring…

Read More NY Court of Appeals Holds “Ministerial Exception” Bars Plaintiff’s Discrimination Claim; Declines to Rule on Scope of “Recreational Activities” Discrimination Statute
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