Hostile Work Environment

In New York City, we wear our high-pressure work environments like a badge of honor. From tech hubs in Flatiron to finance towers on Wall Street and ad agencies in SoHo, office culture is fast, loud, and competitive. But there’s a massive line between standard workplace interpersonal chaos and actionable, unlawful employment discrimination—and too many…

Read More When “Office Drama” Crosses the Discrimination Line
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In Golat v. Skwierawski, No. 25-3164, 2026 WL 2240697 (7th Cir. Aug. 4, 2026), the U.S. Court of Appeals for the Seventh Circuit, inter alia, affirmed the decision of a lower court granting summary judgment to defendants on plaintiff’s sex-based hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964.…

Read More Title VII Sex-Based Hostile Work Environment Claim Summary Judgment Dismissal Affirmed; Comments Not Construed as Sexual Advances
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In Glazman v. Citigroup, Inc., No. 8:26-CV-1522-TPB-AEP, 2026 WL 2253820 (M.D. Fla. Aug. 5, 2026), an employment discrimination case, the court, inter alia, held that the arbitration agreement in question was enforceable, and that the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act (“EFAA”) did not preclude its enforcement. The central issue in…

Read More Sexual Harassment Claims Insufficiently Alleged; Arbitration Agreement Not Precluded By EFAA
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In Salvetti v. Hillside Children’s Center, No. 24-CV-6586-FPG, 2026 WL 2294388 (W.D.N.Y. Aug. 10, 2026), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s complaint alleging sexual orientation discrimination under the New York State Human Rights Law. From the decision: Hostile work environment claims under both [federal law] and the NYSHRL are governed by…

Read More NYSHRL Sexual Orientation Discrimination Claim Dismissed; Court Cites Plaintiff’s Failure to Identify Comparators
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In Rogers-Walker v. Brivo, Inc., No. TJS-25-3213, 2026 WL 2275654 (D. Md. Aug. 6, 2026), 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: A plaintiff’s “[w]orking conditions form a hostile work environment when they are…

Read More Hostile Work Environment Claim Dismissed; Allegations Involved “Unfavorable Personnel Decisions” and the “Uncomfortable Aftermath of Those Decisions”
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In Holmes v. United States Steel Corporation, No. 2:23-CV-359-JEM, 2026 WL 2279295 (N.D. Ind. Aug. 6, 2026), the court, inter alia, dismissed plaintiff’s hostile work environment claim under Title VII of the Civil Rights Act of 1964, finding that plaintiff failed to “exhaust” that claim before the U.S. Equal Employment Opportunity Commission (EEOC). From the…

Read More Title VII Hostile Work Environment Claim Dismissed as Not Administratively Exhausted at the EEOC; Checking Box Held Insufficient
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In Wrightson v. Secretary of the Treasury, No. 25-13676, 2026 WL 2254495 (11th Cir. Aug. 5, 2026), the court affirmed the dismissal of plaintiff’s sex-based hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: In order to sufficiently plead a hostile work environment, an employee must…

Read More Title VII Sex-Based Hostile Work Environment Claim Dismissal Affirmed
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In Bates v. Leviton Manufacturing Co., Inc., No. 3:24-CV-01414, 2026 WL 2211556 (M.D. Tenn. July 31, 2026), the court, inter alia, granted defendant’s motion for summary judgment on plaintiff’s claim of race-based hostile work environment asserted under Title VII of the Civil Rights Act of 1964. Among other allegations was that another employee told plaintiff…

Read More Title VII Race-Based Hostile Work Environment Claim Dismissed; Rumor of “Slave” Comment Insufficient
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In Kosiba v. Dental Associates, PC, No. 2:24-CV-12069-TGB-EAS, 2026 WL 2211548 (E.D. Mich. July 31, 2026), the court, inter alia, granted defendant’s motion for summary judgment on plaintiff’s claims of hostile work environment and sexual harassment asserted under Title VII of the Civil Rights Act of 1964. After concluding that plaintiff had abandoned these claims,…

Read More Title VII Hostile Work Environment Sexual Harassment Complaint Dismissed, Absent Evidence of Report of Harassment
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In Dufour v. Havas Gemini, LLC, No. 25-CV-8915 (LAP), 2026 WL 2185298 (S.D.N.Y. July 29, 2026), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s failure-to-promote claim. From the decision: The only alleged incident within the limitations period of the Title VII and ADEA claims is Plaintiff’s termination. Even considering Plaintiff’s other allegations as…

Read More Discriminatory Failure-to-Promote Claim Dismissed; Plaintiff Did Not Allege That He Applied For the Position
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