Hostile Work Environment

In White v. Children’s Network of Southwest Florida LLC, No. 2:24-CV-00697-KCD-NPM, 2026 WL 98768 (M.D. Fla. Jan. 14, 2026), the court, inter alia, granted defendants’ motion to dismiss plaintiff’s hostile work environment claim. From the decision: As for the hostile work environment claim, employers can be liable when, despite not taking any tangible adverse action,…

Read More Age-Based Hostile Work Environment (ADEA( Claim Dismissed; “Old” Comments Insufficient to State a Claim
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In Poteat v. CP Development et al, No. 24-3290, 2026 WL 93129 (3d Cir. Jan. 13, 2026), the U.S. Court of Appeals for the Third Circuit affirmed a lower court’s granting of defendants’ motion to dismiss plaintiff’s claims of race discrimination and hostile work environment under 42 U.S.C. § 1981. The court summarized the facts,…

Read More Third Circuit Affirms Dismissal of Race Discrimination Claims Asserted Under 42 U.S.C. § 1981
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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 Garcia v. ECPI Univ. LLC, No. 2:25-CV-245, 2026 WL 66749 (E.D. Va. Jan. 8, 2026), the court held that plaintiff alleged a “sexual harassment dispute” under the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 (EFAA), and thus denied defendant’s motion to compel arbitration of plaintiff’s claim under Title IX…

Read More Sexual Harassment Claim Stated Under Title IX; Motion to Compel Arbitration Denied Under EFAA
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In Draghi v. New York City Department of Education, No. 24-CV-2920 (EK)(MMH), 2026 WL 73970 (E.D.N.Y. Jan. 9, 2026), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s claim of hostile work environment asserted under the Americans with Disabilities Act (ADA). From the decision: To allege a hostile work environment, “a plaintiff must show…

Read More Disability-Based Hostile Work Environment Claim, Asserted Under ADA, Dismissed
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In Panchumarthi v. Tech Mahindra, No. 4:24-CV-01017-SDJ-BD, 2025 WL 3687142 (E.D. Tex. Dec. 15, 2025), the court held that the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act (EFAA) did not apply to plaintiff’s claims of discrimination (as opposed to sexual harassment). From the decision: Although the EFAA carves out some sex-discrimination claims,…

Read More Sexual Harassment Not Alleged; EFAA Did Not Apply to Sex Discrimination Claims
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In Mukhina v. Walmart, Inc., No. 24-11586, 2025 WL 3703679 (11th Cir. Dec. 22, 2025), the U.S. Court of Appeals for the Eleventh Circuit, inter alia, affirmed a lower court’s award of summary judgment to defendant on plaintiff’s claim of national origin discrimination (in the form of a hostile work environment) asserted under Title VII…

Read More Accent-Based National Origin Hostile Work Environment Claim Dismissal Affirmed
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In Sheehan v. Everstory Partners et al, No. CV 24-6581, 2025 WL 3727863 (E.D. Pa. Dec. 23, 2025), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s hostile work environment sexual harassment claims. As to one plaintiff, the court explained: Defendants argue that the Amended Complaint fails to allege the first element of a…

Read More Hostile Work Environment Sexual Harassment Claims Survive Dismissal
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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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