Hostile Work Environment

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In Langlois v. Hartford Board of Education et al, 2020 WL 6278722 (2d Cir. Oct. 27, 2020) (Summary Order), the court, inter alia, affirmed the dismissal on summary judgment of plaintiff’s race-based hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. The court wrote: [W]e agree with the district…

Read More Race-Based Hostile Work Environment Claim Properly Dismissed; Most Conduct Was “Reasonably Expected” in the School Environment
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In Cardwell v. Davis Polk & Wardwell LLP et al, 19-cv-10256, 2020 WL 6274826 (S.D.N.Y. Oct. 24, 2020), the court, inter alia, dismissed plaintiff’s race-based hostile work environment claim. In sum, plaintiff – a law firm associate – alleged (inter alia) that he was suffered a hostile work environment on account of his race, in…

Read More Race-Based Hostile Work Environment Claim Dismissed; Social Ostracism Insufficient
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In Lax v. City University of New York et al, 2020 WL 6161253 (EDNY Oct. 21, 2020), the court, inter alia, dismissed plaintiff’s hostile work environment claim. The court summarized the “black-letter law” as follows: A hostile work environment claim requires a showing: (1) that the harassment was “sufficiently severe or pervasive to alter the…

Read More Hostile Work Environment Claim Dismissed, as it was Largely Based on Conduct Experienced by Others
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In Clarke v. New York City Department of Education et al, 2020 WL 6047426 (E.D.N.Y. Oct. 13, 2020), the court, inter alia, granted in part and denied in part defendants’ motion for summary judgment on plaintiff’s gender/pregnancy-based hostile work environment claims. Specifically, the court granted the motion regarding plaintiff’s claims under Title VII of the Civil Rights…

Read More Pregnancy-Related Hostile Work Environment Claims Survive Summary Judgment in Part Against the New York City Department of Education
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Ordinarily I write about decisions issued by New York state courts, federal district courts located in New York, the U.S. Court of Appeals for the 2nd Circuit, and, of course, the U.S. Supreme Court. Here, however, I’ll make an exception and stray from these jurisdictional/geographic limits, in order to discuss a decision issued by the…

Read More “N-Word” Did Not Give Rise to Hostile Work Environment: SCOTUS-Nominee Amy Coney Barrett
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In Rodriguez v. County of Nassau, Nassau County Commission on Human Rights, 2020 WL 5948904 (2d Cir. Oct. 8, 2020) (Summary Order), the court, inter alia, affirmed the dismissal of plaintiff’s gender and national origin-based hostile work environment claim. After outlining the “black-letter law” relating to this claim, the court summarized plaintiff’s contentions: In support…

Read More Hostile Work Environment Claim Dismissal Affirmed; “Handful of Comments Made Over a Decade” Held Insufficient
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In Antoine v. Brooklyn Maids 26, Inc. et al, 19-cv-5676, 2020 WL 5752186 (E.D.N.Y. Sept. 26, 2020), the court, inter alia, awarded a sexual harassment plaintiff $375,000 in punitive damages (on default). This case involves shocking allegations of sexual harassment (which included, in the court’s description, conduct that was “tantamout to rape”). The reader is…

Read More $375,000 Punitive Damages Award to Sexual Harassment Plaintiff
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In Antoine v. Brooklyn Maids 26, Inc. et al, 19-cv-5676, 2020 WL 5752186 (E.D.N.Y. Sept. 26, 2020), the court, inter alia, awarded a sexual harassment plaintiff $200,000 in emotional distress damages (on default). This case involves shocking allegations of harassment, including on one occasion conduct that the court described as “tantamount to rape.” As to…

Read More $200,000 Emotional Distress Award in Sexual Harassment Case Against Brooklyn Maids 26, Inc. and Individual Defendant
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In a recent case, Rubert v. Daniel King, et al, 2020 WL 5751513 (SDNY Sept. 25, 2020), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s hostile work environment claim asserted under 42 U.S.C. § 1981. After summarizing the relevant law, the court applied it to the facts: Here, Plaintiff’s hostile work environment claims…

Read More Race-Based Hostile Work Environment Claim Sufficiently Alleged Against Walmart et al Under 42 U.S.C. § 1981
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In Milord-Francois v. The New York State Office of the Medicaid Inspector General et al, 2020 WL 5659438 (SDNY Sept. 23, 2020), the court, inter alia, granted defendants’ motion for summary judgment on plaintiff’s hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. The Court explained that plaintiff’s hostile…

Read More Hostile Work Environment Claim Dismissed; Conduct by Subordinate Employee Held Insufficient
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