Hostile Work Environment

In Farmer v. Mizuho Securities USA LLC, No. 151348/2024, 2025 WL 1786172 (N.Y. Sup Ct, New York County June 25, 2025), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s allegations of retaliation under the New York State and City Human Rights Laws. From the decision: [P]laintiff alleged that in early December 2020 and…

Read More Retaliation Claims Survive Dismissal, Allegations Included Acceptance of “Resignation” Following Complaints of “Sexist Attitude” Under NYS and NYC Human Rights Laws
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In Shinn v. Pennsylvania School Boards Association, CIVIL NO. 1:23-cv-02097, 2025 WL 1839494 (M.D.Pa. July 3, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s claim of hostile work environment sexual harassment asserted under Title VII of the Civil Rights Act of 1964. From the decision: Here, Shinn’s alleged workplace harassment was neither…

Read More Title VII Hostile Work Environment Sexual Harassment Claim Dismissed; Leave to Amend Complaint Granted
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In Williams v. NYC DSS-HRA, No. 101114/2024, 2025 WL 1810234 (N.Y. Sup Ct, New York County July 01, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s age-based hostile work environment claim under the New York City Human Rights Law. From the decision: Plaintiffs also attempt to plead a hostile work environment under…

Read More Hostile Work Environment Claim Dismissed; Allegations Evidenced “Workplace Frustration ” and “Inter-Personal Issues”
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In Vargas v. City of New York, No. 151379/2024, 2025 WL 1797597 (N.Y. Sup Ct, New York County June 30, 2025), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s claims of race- and gender-based discrimination and hostile work environment claims asserted under the New York State and City Human Rights Laws. From the…

Read More Race, Sex Discrimination & Hostile Work Environment Claims Sufficiently Alleged Against City of New York
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In Esqueda, M.D., Jonathan v. NYU Langone Hospitals, 2025 WL 1785870 (SDNY June 27, 2025), the court, inter alia, granted defendants’ motion for summary judgment on plaintiff’s race- and national origin-based hostile work environment claims asserted under Title VII of the Civil Rights Act and 42 U.S.C. § 1981. After summarizing the black-letter law applicable…

Read More Race, National Origin-Based Hostile Work Environment Claims Dismissed; Alleged Mocking of Accent Insufficient
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In Zimpfer v. Hilbert College, Case No. 1:21-cv-231, 2025 WL 1758266 (W.D.N.Y. June 25, 2025), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s hostile work environment claim asserted under the (amended) New York State Human Rights Law. From the decision: As to the NYSHRL hostile-work-environment claim, Defendants cite authority indicating that…

Read More Hostile Work Environment Claim Sufficient to Withstand Summary Judgment Under Newly-Amended NYS Human Rights Law
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In Collins, Sam v. Federal Express Corporation, 2025 WL 1764809 (2d Cir. June 26, 2025), the U.S. Court of Appeals for the Second Circuit, inter alia, affirmed the lower court’s dismissal of plaintiff’s hostile work environment claims as being time-barred. From the decision: We also agree that Collins’ hostile-work-environment claims are time-barred. A hostile work…

Read More Hostile Work Environment Claims Against FedEx Properly Dismissed as Time-Barred, 2nd Circuit Holds
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In Simmons v. Baccarat Inc., No. 651516/2023, 2025 WL 1735659 (N.Y. Sup Ct, New York County June 23, 2025), the court, inter alia, granted plaintiff’s motion to dismiss plaintiff’s claims of hostile work environment and sexual harassment under the New York State and City Human Rights Laws. From the decision: The Moving Defendants correctly assert…

Read More Hostile Work Environment, Sexual Harassment Claims Dismissed; Evidence Indicated That Plaintiff Participated in “Sexually Themed” Text Messages
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In Kapllanaj v. Healthfirst PHSP, Inc., No. 152720/2021, 2025 WL 1707852 (N.Y. Sup Ct, New York County June 17, 2025), the court, inter alia, denied defendants’ motion for summary judgment on plaintiff’s gender discrimination and hostile work environment claims asserted under the New York State and City Human Rights Laws. The court summarized the facts…

Read More Sexual Harassment Claims Against Healthfirst Survive Summary Judgment
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In Samuel v. Institute for Community Living, Inc., No. 150885/2024, 2025 WL 1180332 (N.Y. Sup Ct, New York County Apr. 22, 2025), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s employment discrimination, hostile work environment, and retaliation claims. The court summarized the facts as follows: Plaintiff alleges she always performed her work satisfactorily…

Read More Age Discrimination, Hostile Work Environment, Retaliation Claims Survive Dismissal; Allegations Include “Old Bitch”, “Fat Loser”, and “Piece of Crap” Comments
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