NYS Human Rights Law

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In Mwangi v. Passbase, Inc. et al, 21-cv-6728, 2022 WL 2133734 (S.D.N.Y. June 14, 2022), the court, inter alia, dismissed plaintiff’s discrimination claims under 42 U.S.C. § 1981. At all relevant times, plaintiff worked remotely from Berlin, Germany, and was not in the U.S. when the alleged discrimination took place. As to plaintiff’s § 1981…

Read More Germany-Based Plaintiff’s Discrimination Claims Dismissed on Geographic Grounds
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In Kirstyn Crawford v. American Broadcasting Co., Inc., No. 157874/2021, 2022 WL 2066925 (N.Y. Sup Ct, New York County June 08, 2022), the court granted individual defendant Michael Corn’s motion to dismiss plaintiff’s hostile work environment sexual harassment claims, asserted under the New York State and City Human Rights Laws, as time-barred. Plaintiff (an ABC…

Read More Hostile Work Environment Sexual Harassment Claims Dismissed, as Time-Barred, Against Former ABC Producer Michael Corn
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In Ilana Gamza-Machado de Souza v. Planned Parenthood Federation of America, Inc. et al, 21 Civ. 5553 (LGS), 2022 WL 2047580 (S.D.N.Y. June 7, 2022), the court held that plaintiff, a Jewish woman, plausibly alleged retaliation claims under Title VII of the Civil Rights Act of 1964, the New York State Human Rights Law, and…

Read More Jewish Woman Sufficiently Alleges Retaliation Against Planned Parenthood
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In Oluwo v. Sutton, No. 2019-13814, 2260/19, 2022 N.Y. Slip Op. 03734, 2022 WL 2057838 (N.Y.A.D. 2 Dept. June 08, 2022), the Appellate Division, Second Department modified a lower court order, and held that plaintiff sufficiently alleged claims of national origin-based discrimination (under the New York State Human Rights Law), and hostile work environment (under…

Read More Nigerian Plaintiff’s National Origin Discrimination and Hostile Work Environment Claims Should Have Not Have Been Dismissed, Court Holds
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In Estevez, Mancini, and Mekuli v. Berkeley College et al, No. 18-CV-10350 (CS), 2022 WL 1963659 (S.D.N.Y. June 6, 2022), an employment discrimination case, the court considered defendants’ motion for attorney fees following the court’s prior summary judgment dismissal of plaintiff’s claims. Many of the anti-discrimination laws – including Title VII of the Civil Rights…

Read More Court Finds That “Thin” Retaliation Claims Were Not “Frivolous” so as to Warrant an Award of Attorney Fees to Defendants; Cautions Plaintiffs’ Counsel
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In Blackman v. Metropolitan Transit Authority, NYC Transit Authority et al, No. 2019-09440, Index 502489, 2022 WL 1760133 (N.Y.A.D. 2 Dept. June 01, 2022), the court, inter alia, held that the lower court properly denied defendants’ motions for summary judgment on plaintiff’s race-based failure-to-hire and failure-to-promote claims asserted under the New York State and City…

Read More Discriminatory Hiring, Promotion Claims Survive Summary Judgment Against NYC Transit Authority
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In Jones v. CareandWear II, Inc., No. 656428/2020, 75 Misc. 3d 1205(A), 2022 N.Y. Slip Op. 50383(U), 2022 WL 1483791 (N.Y. Sup. Ct. N.Y. Cty. May 10, 2022), the court, inter alia, held that plaintiff sufficiently alleged a claim of gender discrimination and hostile work environment under the New York State and City Human Rights…

Read More Sex/Gender Harassment & Hostile Work Environment Claims Survive Against CareandWear II, Inc.
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In Brager v. Quality Bldg. Services Corp., No. 155832/2021, 2022 WL 1599529 (N.Y. Sup. Ct. NY Cty. May 20, 2022), the court, inter alia, dismissed plaintiff’s age and national origin-based hostile work environment claim as insufficiently pled. As to plaintiff’s age discrimination claim, the court explained: Plaintiff’s allegations regarding the alleged hostile work environment related…

Read More Hostile Work Environment Claims Insufficiently Alleged; Being Jewish Was Not a “National Origin” Category
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In Makhsudova v. City of New York et al, 2022 WL 1571152 (S.D.N.Y. May 18, 2022), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s hostile work environment claims under Title VII of the Civil Rights Act of 1964, the New York State Human Rights Law, and the New York City Human Rights Law.…

Read More Hostile Work Environment Claims, Asserted by Muslim Uzbek Woman, Survive Dismissal
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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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