In Gehlaut v. New York City Department of Education, No. 24-1741 (2d Cir. 2025), the U.S. Court of Appeals for the Second Circuit affirmed the dismissal of plaintiff’s retaliation claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: To state a claim for retaliation under Title VII, “the plaintiff…
Read More Title VII Retaliation Claim Properly Dismissed; Temporal Proximity Not ShownIn Caldrone v. Circle K Stores Inc., 2025 WL 2811320 (9th Cir. Oct. 3, 2025), the U.S. Court of Appeals for the 9th Circuit reversed and remanded the lower court’s award of summary judgment dismissing plaintiffs’ allegations of age discrimination (failure to promote) under the Age Discrimination in Employment Act (ADEA). The court proceeded to…
Read More ADEA Age Discrimination (Failure to Promote) Claims Resurrected From Summary Judgment DismissalIn Legare v. City of New York, No. 159418/2024, 2025 WL 2840633 (N.Y. Sup Ct, New York County Oct. 6, 2025), an employment discrimination case, the court discussed and applied New York’s venue provision, New York Civil Practice Law and Rules (CPLR) 504. From the decision: In support of the instant motion, defendants highlight that…
Read More Court Grants Motion Changing Venue from Manhattan to Staten Island in Hostile Work Environment CaseIn Izuogu v. Credit Agricole Corporate and Investment Bank, New York, 24 Civ. 4329 (DEH), 2025 WL 2806683 (S.D.N.Y. Oct. 2, 2025), the court, inter alia, granted defendants’ motion to dismiss plaintiff’s hostile work environment claims under Title VII of the Civil Rights Act of 1964 and 42 U.S.C. 1981. From the decision: To establish…
Read More Hostile Work Environment Claims Dismissed; Remarks, Gossip, False Complaint Did Not Reference Race or National OriginIn Smith v. Meta Platforms, Inc., 24 Civ. 4633 (JPC), 2025 WL 2782484 (S.D.N.Y. Sept. 30, 2025), the court held that a party invoking the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 (EFAA) must actually allege facts that constitute sexual harassment. Here, the plaintiff did not: To determine whether this…
Read More Non-Sexual Gender Discrimination Did Not Trigger EFAA’s Arbitration BarIn Mehta, Anisha v. DLA Piper LLP, 23 Civ. 4757 (AT), 2025 WL 2771659 (S.D.N.Y. Sept. 29, 2025), the court denied defendant’s motion for summary judgment on plaintiff’s claims of pregnancy discrimination asserted under Title VII of the Civil Rights Act of 1964, the New York State Human Rights Law, and the New York City…
Read More Pregnancy Discrimination Claims Survive Summary Judgment Against DLA PiplerIn Batayneh v. Reunited Clothing, LLC, No. 152829/2025, 2025 WL 2682960 (N.Y. Sup Ct, New York County Sep. 18, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s promissory estoppel claim. This decision illustrates the difficulty of asserting common-law claims in the “at will” employment context. Specifically: Plaintiff claims Reunited hired her as…
Read More At-Will Employee’s Promissory Estoppel Claim DismissedIf you believe you’ve been subjected to employment discrimination, knowing your rights is the crucial first step toward justice. The U.S. Equal Employment Opportunity Commission (EEOC) is the federal agency responsible for enforcing various federal laws that make it illegal to discriminate against a job applicant or an employee based on various protected characteristics. Importantly,…
Read More Know Your Rights: A Guide to Filing a Complaint with the EEOCIn Schneidermesser v. NYU Grossman School of Medicine, 2025 WL 2732877 (S.D.N.Y. Sept. 25, 2025), the court, inter alia, denied defendant’s motion for reconsideration of the court’s denial of its motion for summary judgment as to plaintiff’s age-based hostile work environment claim. From the decision: NYU Langone raises two arguments in its motion. First, it…
Read More Age-Based Hostile Work Environment Claim Survives Summary Judgment; Motion for Reconsideration DeniedIn Pullman et al v. Collins et al, No. 24-CV-1383 (KMK), 2025 WL 2673807 (S.D.N.Y. Sept. 18, 2025), the court, inter alia, denied defendants’ motion to dismiss a plaintiff’s claim of hostile work environment sexual harassment asserted under the New York State Human Rights Law. From the decision: Next, Defendants argue that Dinsmore has failed…
Read More Sexual Harassment Claim Sufficiently Alleged Under Recently-Amended NYS Human Rights Law, Court Holds