Judge Townes

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In Yang v. Dep’t of Educ. of the City of New York, 2016 WL 4028131 (E.D.N.Y. July 26, 2016), the court denied defendant’s FRCP 12(b)(6) motion to dismiss plaintiff’s disparate treatment and hostile work environment claims based on her national origin (Chinese). As to plaintiff’s hostile work environment claim, the court explained: [T]he Court concludes…

Read More National Origin (Chinese) Disparate Treatment and Hostile Work Environment Claims Plausibly Alleged
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In Deberry v. Brookdale Univ. Hosp. & Med. Ctr., No. 12-CV-6251(SLT)(RLM), 2016 WL 3840673 (E.D.N.Y. July 12, 2016), the court dismissed plaintiff’s discrimination, harassment, and hostile work environment claims. Here I’ll focus on its discussion of plaintiff’s hostile work environment claim. This case is instructive on the issue of when the alleged harassment may be…

Read More Court Discusses the “Imputing Conduct” Element of a Hostile Work Environment Claim
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A recent decision, DeLaurencio v. Brooklyn Children’s Center, Superintendent (EDNY May 29, 2015), reiterates that Title VII is not a “general civility code” and that “[w]ork environments that are hostile for non-discriminatory reasons do not fall within the ambit of Title VII.” In this case, the court held that none of the allegations in plaintiff’s…

Read More Employment Discrimination / Hostile Work Environment Allegations Amounting to Rude Conduct Unmotivated by Discriminatory Animus Fail to State a Claim
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In Suarez v. City of New York (EDNY 11-cv-5812 March 31, 2015), the Eastern District of New York dismissed the claims by plaintiff, a deckhand on the Staten Island Ferry (and employed by the NYC Department of Transportation), that she was sexually harassed by Warren, an AlliedBarton security guard, under the NYC Human Rights Law (NYCHRL). Addressing…

Read More Staten Island Ferry Security Company Not Liable For Sexual Harassment Perpetrated by its Employee Against Non-Employee Deckhand
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