NYS Human Rights Law

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In Whipple v. Reed Eye Associates, 15-CV-6759L, 2021 WL 852039 (W.D.N.Y. March 8, 2021), the court, inter alia, granted defendants’ motion to dismiss plaintiff’s sex-based hostile work environment claim. While the court ultimately ruled against the plaintiff on the merits, this decision is nevertheless instructive as to how courts evaluate the situation where some events…

Read More Court Dismisses Sex-Based Hostile Work Environment Claims; Discusses “Out-of-Office” Conduct
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In Moazzaz v. MetLife, Inc. et al, 2021 WL 827648 (S.D.N.Y. March 4, 2021) (J. Oetken), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s discriminatory failure-to-promote claims under the New York State Human Rights Law (NYSHRL) and the New York City Human Rights Law (NYCHRL). (The court also held that plaintiff sufficiently alleged…

Read More Failure-to-Promote Claims Sufficiently Alleged Against MetLife
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In Moazzaz v. MetLife, Inc. et al, 2021 WL 827648 (S.D.N.Y. March 4, 2021) (J. Oetken), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s claims of gender-based hostile work environment under the New York State Human Rights Law (NYSHRL) and the New York City Human Rights Law (NYCHRL). Here is the court’s discussion…

Read More Gender-Based Hostile Work Environment Claims Sufficiently Alleged Against MetLife
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In Rollag v. Cowen Inc. et al, 2021 WL 807210 (S.D.N.Y. March 3, 2021) – in which the plaintiff alleges that defendants discriminated and retaliated against him in violation of the Family and Medical Leave Act, 29 U.S.C. §§ 2601 et seq., Section 806 of the Sarbanes-Oxley Act of 2002, 18 U.S.C. § 1514A, and…

Read More Arbitration Compelled in Employment Discrimination Case; FAA Held to “Displace” CPLR 7515 Here
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In Beards et al v. Bronxcare Health System et al, 2021 WL 704177 (S.D.N.Y. Feb. 23, 2021), the court dismissed plaintiffs’ claims of race- and religion-based discrimination 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. After concluding that…

Read More Citing Productivity Decline, Court Dismisses Race and Religion-Based Discrimination Claims
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In Crawford v. The Goldman Sachs Group, Inc., et al.; Index No. 159731/2020 (Feb. 23, 2021), an employment discrimination/retaliation case, New York Supreme Court Justice Paul Goetz issued a (relatively terse) order granting defendants’ motion to compel arbitration, reasoning that “the claims fall within the scope of the arbitration clause and are not barred by…

Read More Discrimination Claims Must Be Arbitrated Against Goldman Sachs, Court Rules
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In Black v. ESPN, Inc. et al, No. 155236/2020, 2021 N.Y. Slip Op. 50118(U), 2021 WL 668760 (Sup Ct NY Cty, Feb. 19, 2021), the court denied defendants’ motion to dismiss plaintiff’s disability discrimination, hostile work environment, and retaliation claims asserted under the New York State and City Human Rights Laws. In sum, plaintiff, a…

Read More Disability Discrimination, Hostile Work Environment, & Retaliation Claims Sufficiently Alleged Against ESPN et al
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In Domingues v. Barton Chevrolet Cadillac et al, 18-CV-07772, 2021 WL 637016 (S.D.N.Y. Feb. 17, 2021), the court, inter alia, denied defendant Barton Chevrolet’s motion for summary judgment on plaintiff’s sexual harassment/hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964 and the New York State Human Rights Law. The…

Read More Sexual Harassment Hostile Work Environment Survives Summary Judgment; Breast Touching & Comments Presented Triable Issues of Fact
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In Perrotte v. Bloomberg, LP et al, No. 451470/2020, 2021 WL 465986 (N.Y. Sup Ct, New York County Feb. 09, 2021), the court, inter alia, dismissed plaintiff’s “quid pro quo” sexual harassment claim asserted under the New York State Human Rights Law. The court summarized the law as follows: Pursuant to NYSHRL, it is an…

Read More Quid Pro Quo Sexual Harassment Claim Dismissed Against Bloomberg LP et al
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In Madrigal v. Montefiore Medical Center et al., No. 12306, 2020-00608, 307949/10E, 2021 N.Y. Slip Op. 00526, 2021 WL 329412 (N.Y.A.D. 1 Dept., Feb. 02, 2021), the court, inter alia, upheld damage awards for plaintiff on her gender discrimination, sexual harassment, and retaliation claims. (The court’s discussion of liability is discussed here.) A jury awarded…

Read More Court Reverses Damages Reductions in Sexual Harassment Case Against Montefiore Medical Center
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