Hostile Work Environment

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In 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
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In Vannier v. New York State Department of Corrections and Community Services et al, 2025 WL 345807 (N.D.N.Y. Jan. 30, 2025), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. In sum, plaintiff – a transgender man who worked…

Read More Hostile Work Environment Sufficiently Alleged; Allegations Include Assignment to Unsuitable Workspace
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In Ashley Newbury v. City of Niagara Falls, No. 23-7976-cv, 2025 WL 323340 (2d Cir. 2025), the U.S. Court of Appeals for the Second Circuit affirmed the lower court’s summary judgment dismissal of plaintiff’s hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: Superintendent DalPorto is…

Read More Hostile Work Environment Dismissal Affirmed; “Piece of Shit” Comment Insufficient
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In Torres v. City of New York, No. 161278/2023, 2025 WL 248895 (N.Y. Sup Ct, New York County Jan. 15, 2025), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s hostile work environment claim asserted under the New York City Human Rights Law. From the decision: Plaintiff’s allegations of hostile work environment–including discriminatory remarks,…

Read More Hostile Work Environment Claim, Based on Alleged Discriminatory Remarks, Threats of Termination, and Denial of Benefits, Sufficiently Alleged
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In Simms v. The State of Maryland Office of the Attorney General For Maryland, 2025 WL 213965 (D.Md. Jan. 16, 2025), the court, inter alia, dismissed plaintiff’s hostile work environment sexual harassment claim. From the decision: The Court need not decide whether Plaintiff has adequately alleged facts sufficient to “impos[e] liability on the employer” for…

Read More Hostile Work Environment Sexual Harassment Claim Dismissed; Allegations of Staring and Stalking Insufficient
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In Bhuiyan v. Department of Treasury, 2025 WL 79634 (S.D.Ohio Jan. 13, 2025), the court adopted a Magistrate Judge’s Report & Recommendation granting defendant’s motion to dismiss plaintiff’s hostile work environment sexual harassment claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: “Sexual harassment that results in a ‘hostile…

Read More Title VII Hostile Work Environment Sexual Harassment Claim Dismissed, Buttcrack Exposure Notwithstanding
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In Rios v. Max Mara USA Inc. et al, No. 23-CV-9839 (LAP), 2025 WL 66502 (S.D.N.Y. Jan. 10, 2025), the court, inter alia, granted defendant’s motion for judgment on the pleadings (under Federal Rule of Civil Procedure 12(c)) on plaintiff’s claim of hostile work environment sexual harassment asserted under Title VII of the Civil Rights…

Read More Hostile Work Environment Sexual Harassment Claim Dismissed; Pretend Breast “Motorboating” Insufficiently “Severe”
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In Dixon v. City of New York, 23-cv-8941 (JGK), 2025 WL 50140 (S.D.N.Y. Jan. 7, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s disability-based hostile work environment claims. This decision illustrates that generalized objectionable conduct – such as what might be considered “verbal harassment” – is alone insufficient to constitute an actionable…

Read More Disability-Based Hostile Work Environment Claims Dismissed; Allegation of Being Addressed in a “Loud, Aggressive and Belligerent Tone” Insufficient
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In Smith v. Louis DeJoy, 2024 WL 5145956 (N.D.Ala. Dec. 17, 2024), the court, inter alia, granted defendant’s motion for summary judgment dismissing plaintiff’s hostile work environment claim. From the decision: Plaintiff’s termination was a single discrete event. So, in the absence of pervasiveness, the only way for her hostile work environment claim to survive…

Read More Hostile Work Environment Claim Dismissed; Termination Was Not Sufficiently “Severe”
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In Brooks v. Liberty Mutual Insurance Co., 2024 WL 5186527 (S.D.N.Y. Dec. 20, 2024), an employment discrimination/hostile work environment case, the court dismissed plaintiff’s third amended complaint (TAC). Interestingly, the court did not address the merits, but rather focused on the procedural requirements for such a complaint: Rule 8(a)(2) of the Federal Rules of Civil…

Read More 100+ Page Hostile Work Environment Complaint Dismissed as Being Neither “Short Nor Plain”
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