In Coley v. Lead Sec. Group Inc., No. 152480/2023, 2025 WL 317653 (N.Y. Sup Ct, New York County Jan. 22, 2025), the court denied defendants’ motion to dismiss plaintiff’s employment discrimination claims. This decision illustrates the relatively low bar defining a plaintiff’s pleading obligation under the New York State and City Human Rights Laws: On…
Read More Employment Discrimination Claims Survive Dismissal, Court HoldsIn Jones v. Fluor Facility & Plant Services, No. 24-5249, 2025 WL 707869 (6th Cir. 2025), the U.S. Court of Appeals for the Sixth Circuit reversed a lower court’s award of summary judgment dismissing plaintiff’s race-based hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. After summarizing the elements…
Read More Race-Based Hostile Work Environment Claim Withstands Summary Judgment; 6th Circuit Reverses Summary Judgment DismissalIn Walls v. City of New York, No. 156492/2024, 2025 WL 697108 (N.Y. Sup Ct, New York County Mar. 04, 2025), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s hostile work environment claim on statute of limitations grounds. In doing so, the court applied the “continuing violation doctrine”: Defendants argue that Plaintiff’s claims…
Read More Applying “Continuing Violation Doctrine”, Court Rejects Statute of Limitations Challenge to Hostile Work Environment ClaimsIn Bamba v. United States Department of Homeland Security, Kristi Noem, 2025 WL 670188 (2d Cir. 2025), the U.S. Court of Appeals for the Second Circuit affirmed the lower court’s dismissal of plaintiff’s claim of race-based hostile work environment asserted under Title VII of the Civil Rights Act of 1964. From the decision: Bamba’s hostile…
Read More 2nd Circuit: Title VII Race-Based Hostile Work Environment Claim Properly DismissedIn Delancey v. Justin Wells, Fox Corporation, and Fox News Network, LLC, 23 Civ. 10357 (AT), 2025 WL 579971 (S.D.N.Y. Feb. 21, 2025), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s claim of hostile work environment sexual harassment asserted under the New York State Human Rights Law (which, explained the court, employs the…
Read More Hostile Work Environment Sexual Harassment Claim Sufficiently Alleged Against FoxIn White v. Roosevelt Union Free School District Board of Education, 15-CV-1035(JS)(JMW), 2025 WL 552744 (E.D.N.Y. Feb. 19, 2025), the court, inter alia, granted defendant’s motion for summary judgment on the (Caucasian) plaintiff’s claim of race-based hostile work environment asserted under Title VII of the Civil Rights Act of 1964. After summarizing the black-letter law,…
Read More Race-Based Hostile Work Environment Claim Dismissed; “Whitey”, “Asshole”, etc Comments InsufficientIn Martino v. Chenel Capital, LLC et al, No. 2023–04316, 3710, 2025 WL 516143 (N.Y.A.D. 1 Dept., Feb. 18, 2025), the Appellate Division, First Department unanimously reversed a lower court’s decision that the plaintiff failed to establish defendants’ liability for hostile work environment, sex discrimination, and retaliation under the New York State and City Human…
Read More Sex-Based Hostile Work Environment Claims Sufficiently Presented at Inquest; Contrary Decision ReversedIn Denson v. Donald J. Trump for President, Inc., No. 101616/2017, 2025 WL 503245 (N.Y. Sup Ct, New York County Feb. 14, 2025), the court, inter alia, granted defendant’s motion for summary judgment on plaintiff’s sex-based hostile work environment asserted under the New York City Human Rights Law. From the decision: Plaintiff’s hostile work environment…
Read More Sex-Based Hostile Work Environment Claim Dismissed Against Trump CampaignIn Pachura v. Lloyd J. Austin III, 6:21-cv-316 (AMN/MJK), 2025 WL 371786 (N.D.N.Y. Feb. 3, 2025), the court, inter alia, dismissed plaintiff’s hostile work environment sexual harassment claim. While the court found that plaintiff raised a triable issue of fact as to whether the work environment was objectively and subjectively “hostile,” the court found that…
Read More Hostile Work Environment Sexual Harassment Claim Dismissed; Conduct Not Imputable to EmployerIn Armstrong v. Aura Healthcare, LLC, No. 3:24-cv-723 (VAB), 2025 WL 357839 (D.Conn. Jan. 31, 2025), the court, inter alia, held that plaintiff did not sufficiently allege a hostile work environment. From the decision: Ms. Armstrong alleges that she was subjected to an objectively hostile or abusive work environment, as she was subjected to hostile…
Read More Hostile Work Environment Claims Dismissed; “Idiot” Comment Insufficient