Hostile Work Environment

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In Brooks v. Liberty Mutual Insurance Co., 2024 WL 5186527 (S.D.N.Y. Dec. 20, 2024), an employment discrimination/hostile work environment case, the court dismissed plaintiff’s third amended complaint (TAC). Interestingly, the court did not address the merits, but rather focused on the procedural requirements for such a complaint: Rule 8(a)(2) of the Federal Rules of Civil…

Read More 100+ Page Hostile Work Environment Complaint Dismissed as Being Neither “Short Nor Plain”
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In McConaughey v. Port Authority of New York and New Jersey, 21-CV-6137 (RA), 2024 WL 5168018 (S.D.N.Y. Dec. 18, 2024), the court denied defendant’s motion for summary judgment on plaintiff’s sex-based hostile work environment and retaliation claims asserted under Title VII of the Civil Rights Act of 1964. From the decision: McConaughey alleges that he…

Read More Title VII Sex-Based Hostile Work Environment, Retaliation Claims Survive Summary Judgment Against Port Authority
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In Troeger v. JetBlue Airways Corp., 2024 WL 5146185 (S.D.N.Y. December 17, 2024), the court denied defendant’s motion to dismiss plaintiff’s hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. After summarizing the black-letter law, the court applied it to the facts as follows: Here, Troeger does not allege…

Read More Hostile Work Environment Claim Survives Dismissal Against JetBlue, Court Holds
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In Sanchez v. New York City Housing Authority, 23-CV-8683 (JMF), 2024 WL 5119372 (S.D.N.Y. Dec. 16, 2024), the court, inter alia, granted summary judgment to defendant on plaintiff’s sex-based hostile work environment claims. From the decision: Next, Sanchez brings a hostile work environment claim under Title VII. To survive summary judgment on a hostile work…

Read More Sex-Based Hostile Work Environment Claims Dismissed; Employer’s Action Prevented Imputing Alleged Conduct
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In LaChapel v. Brio Solar Energy, LLC et al, 2024 WL 5089561 (N.D.Tex. Dec. 12, 2024), the court denied plaintiff’s motion for a default judgment on his hostile work environment asserted under Title VII of the Civil Rights Act of 1964. From the decision: LaChapel fails to state a cognizable claim for a hostile work…

Read More Hostile Work Environment Claim Fails, as Alleged Discriminatory Statements Were Not “Directed At” Plaintiff
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In Ancrum v. New York City Department of Environmental Protection, 2024 WL 5009145 (S.D.N.Y. Dec. 6, 2024), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s sexual harassment claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: For Title VII purposes, a workplace is actionably hostile when it…

Read More Title VII Sexual Harassment Claim Dismissed; Comments, While “Despicable” and “Offensive”, Held Not Actionable
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In Crump v. City of New York, No. 155802/2013, 2024 WL 4957329 (N.Y. Sup Ct, New York County Nov. 30, 2024), the court, inter alia, dismissed plaintiff’s hostile work environment claims asserted under the New York State and City Human Rights Laws. From the decision: Defendants have demonstrated that the conduct at issue was not…

Read More Hostile Work Environment Claims Dismissed; Alleged Joking About Accent Held Insufficient
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In Adeniji v. The City of New York, No. 152761/2022, 2024 WL 4939661 (N.Y. Sup Ct, New York County Nov. 26, 2024), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s race-based hostile work environment claims under the New York State and City Human Rights Laws. From the decision: Plaintiff opposes this prong of…

Read More Race-Based Hostile Work Environment Claims Survive Dismissal; Allegations Include a History of Maltreatment and Denied Opportunities
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In Sfanos v. Cranberry Crossroads Dining Venture, LLC, 2:23-CV-1502, 2024 WL 4827171 (W.D.Pa. Nov. 19, 2024), the court, inter alia, held that plaintiff sufficiently alleged an age-based hostile work environment claim under the Age Discrimination in Employment Act (ADEA). From the decision: Ms. Sfanos’s age-specific allegations are thinner, but they too are enough for now.…

Read More Age-Based Hostile Work Environment Claim Survives Dismissal
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In Ibhawa v New York State Division of Human Rights, No. 100, 2024 N.Y. Slip Op. 05872, 2024 WL 4884944 (N.Y., Nov. 26, 2024), the New York Court of Appeals held that the the First Amendment’s “ministerial exception” did not deprive the New York State Division of Human Rights (DHR) of jurisdiction over the employee’s…

Read More Hostile Work Environment Claim’s Dismissal Per “Ministerial Exception” Was Erroneous, NY Court of Appeals Holds
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