Hostile Work Environment

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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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In Mazzuchelli v. Immutable Pty. Ltd and Lightsource Global, 23-cv-7885 (NSR), 2024 WL 4817535 (S.D.N.Y. Nov. 18, 2024), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s hostile work environment sexual harassment claim asserted under Title VII of the Civil Rights Act of 1964. The court summarized and applied the law as follows: A…

Read More Title VII Hostile Work Environment Claim Dismissed; Alleged “Graphic Sexual Discussions” and “Sexual Overtures” Notwithstanding
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In Santay v. Ice House LLC, Civil Action No. 24-cv-11583-ADB, 2024 WL 4804967 (D.Mass. Nov. 15, 2024), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s national origin-based hostile work environment claim. After summarizing the black-letter law, and concluding that plaintiff sufficiently alleged a hostile work environment sexual harassment claim, the court applied the law to…

Read More National Origin-Based Hostile Work Environment Claim Sufficiently Alleged; Contentions Included Threats to “Call Immigration”
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In Conlan v. Liberty Mutual Group, Inc. and Charles Bruce Stark, 2024 WL 4792112 (S.D.N.Y. Nov. 13, 2024), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s sex-based hostile work environment claim asserted under the New York State Human Rights Law. The court summarized the facts, in part, as follows: Shortly after Plaintiff began…

Read More Hostile Work Environment Sexual Harassment Claim Sufficiently Alleged Against Liberty Mutual, Court Holds
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In Jean-Pierre v. City of New York, No. 153859/2023, 2024 WL 4753498 (N.Y. Sup Ct, New York County Nov. 12, 2024), the court denied defendant’s motion to dismiss plaintiff’s claims of race discrimination and hostile work environment. From the decision: Plaintiff’s amended complaint alleges sufficient facts to support claims of discrimination and hostile work environment…

Read More Race-Based Discrimination & Hostile Work Environment Claims Sufficiently Alleged Against City of New York, Court Holds
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