Hostile Work Environment

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In Wallace v. Crab House, Inc. et al, 21-cv-5757 (LJL), 2022 WL 1501089 (S.D.N.Y. May 12, 2022), the court dismissed plaintiff’s claims of race discrimination and hostile work environment asserted under federal, state, and local law. In sum, plaintiff (who is African American) alleges that he and two employees of Hispanic descent were treated differently…

Read More Federal (42 U.S.C. § 1981) Race-Based Hostile Work Environment Claim Dismissed; Accusations of Tip Theft Etc. Insufficient
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In Errickson v. Lakeland Regional Medical Center, Inc., 8:22-cv-533-VMC-CPT, 2022 WL 1487588 (M.D.Fla. May 11, 2022), the court dismissed plaintiff’s disability-based hostile work environment claim asserted under the Americans with Disabilities Act. After summarizing the “black letter” law, the court applied it to the facts: Although the issue of whether harassment was severe and pervasive…

Read More “Unpleasant” Conduct Nevertheless Insufficient to Give Rise to a Plausible ADA Hostile Work Environment Claim, Court Holds
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In Nyambi v. Delta Airlines, Inc., No. 2:21-cv-00369-JHC, 2022 WL 1443741 (W.D.Wash. May 6, 2022), the court granted defendant’s motion for summary judgment on plaintiff’s race-based hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: Assuming Plaintiff pleaded a hostile work environment claim, he fails to…

Read More Race-Based Hostile Work Environment Claim Dismissed; Single “Stupid African” Remark Insufficiently “Severe”
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In Howard et al v. Cook County Sheriff’s Office et al, No. 17 C 8146, 2022 WL 1404833 (N.D.Ill. May 4, 2022), the court held that plaintiffs – female corrections officers – presented enough evidence to overcome defendants’ motion for summary judgment on their claims of hostile work environment sexual harassment (by detainees) under Title…

Read More Jail Employees’ Hostile Work Environment Sexual Harassment Claims Survive Summary Judgment
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In Cruse v. Bi-State Development Agency of Missouri-Illinois Metropolitan District, No. 4:20-cv-366-MTS, 2022 WL 1185149 (E.D.Mo. April 21, 2022), the court, inter alia, held that factual issues precluded summary judgment on plaintiff’s claims of sexual harassment. In sum, plaintiff alleged that her supervisor (Brew) sexually harassed her, both in person and by phone, and that…

Read More Sexual Harassment Claim(s) Survive Summary Judgment; Factual Issues Existed as to Whether Harassment Culminated in a “Tangible Employment Action” Etc.
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In Grant v. Baltimore Police Department, No. RDB-21-2173, 2022 WL 1321593 (D.Md. May 3, 2022), the court, inter alia, dismissed plaintiff’s claim of hostile work environment asserted under Title VII of the Civil Rights Act of 1964. This case illustrates that not everything negative that happens to an employee in the workplace will give rise…

Read More Title VII Race- and Gender-Based Hostile Work Environment Claims Dismissed; Single Comments Insufficient
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In Erno v. New York State Office of Information Technology Services, No. 1:19-CV-1457, 2022 WL 1224325 (N.D.N.Y. April 26, 2022), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s hostile work environment sexual harassment claim under Title VII of the Civil Rights Act of 1964 (but not under the New York State Human…

Read More Hostile Work Environment Sexual Harassment Claim, Against NYS Office of Information Technology Services, Survives Summary Judgment
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In Dunham v. Hartford Board of Education, No. HHD-CV-206129681-S, 2022 WL 1223917 (Conn. Super. April 26, 2022), the court, inter alia denied defendant’s motion for summary judgment on plaintiff’s hostile work environment sexual harassment claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: A hostile work environment claim requires…

Read More Sexual Harassment (Hostile Work Environment) Claim Survives Summary Judgment Against Hartford Board of Education
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In Armijo v. Costco Wholesale Warehouse, Inc., No. 19-00484-ACK-RT, 2022 WL 1267254 (D.Hawai’i April 28, 2022), the court, inter alia, granted defendant’s motion for summary judgment on plaintiff’s disability-based hostile work environment claim. The court summarized the pertinent law as follows: A hostile work environment claim relies on a series of separate acts that collectively…

Read More Disability-Based Hostile Work Environment Claim Dismissed Against Costco
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In Durand v. Shull, 2022 WL 1184041 (10th Cir. April 21, 2022), the Tenth Circuit affirmed the lower court’s application of qualified immunity to grant defendant’s motion for summary judgment on plaintiff’s race-based hostile work environment claim. In sum, plaintiff – a Black female who worked as a Youth Services Specialist at a juvenile detention…

Read More Tenth Circuit Affirms Dismissal of Race-Based Hostile Work Environment Claim; Cites Relevance of Prison Context
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