In O’Connor v. Citigroup Global Markets, Inc., No. 158198/2024, 2025 WL 3709253 (N.Y. Sup. Ct. Dec. 17, 2025), the court, inter alia, held that plaintiff failed to state a claim of sex discrimination under the New York City Human Rights Law. After determining that plaintiff not receiving a promotion constituted an “adverse employment action,” it…
Read More Sex Discrimination Claims Against Citigroup DismissedIn Myers v. Doherty, 2025 NY Slip Op 06550 (N.Y. App. Div. 1 Dept. Nov. 25, 2025), the court affirmed the lower court’s order granting defendants’ motion to dismiss plaintiff’s complaint alleging claims of employment discrimination, retaliation, and hostile work environment. From the decision: Plaintiff did not experience an adverse employment action when he was…
Read More Failure to Demonstrate Discriminatory Animus Dooms Discrimination, Retaliation, & Hostile Work Environment Claims, First Department HoldsYesterday, New York Governor Hochul signed the Reasonable Accommodation Anti-Retaliation Act (S3398/A4898), which amends the New York State Human Rights Law (specifically, section 296(7) of the New York Executive Law) to clarify that it shall be an unlawful discriminatory practice to retaliate against an individual for requesting a reasonable accommodation. In particular: This bill closes this…
Read More Governor Hochul Signs Reasonable Accommodation Anti-Retaliation Act (S3398/A4898)In Ghiorse v. John H. Cook, Jr. Painting Contractor, Inc. et al, No. 3:25-CV-1578 (BKS/MJK), 2025 WL 3465995 (N.D.N.Y. Dec. 2, 2025), the court, inter alia, recommended the the district court allow plaintiff’s hostile work environment claim under Title VII o the Civil Rights Act of 1964 to proceed against the entity defendant – but…
Read More Title VII Sex-Based Hostile Work Environment Claim Sufficiently Alleged; Status of Key Actor to be Clarified in Amended ComplaintIn Estep v. Brenner, No. 159639/2022, 2025 WL 3312877 (N.Y. Sup. Ct. Nov. 24, 2025), the court denied plaintiff’s motion to amend their complaint to add a cause of action for race-based discrimination and hostile work environment under federal law (Title VII of the Civil Rights Act of 1964), following the dismissal of plaintiff’s claim…
Read More Motion to Amend Complaint to Add Title VII Race Discrimination, Hostile Work Environment Claims DeniedIn Mera et al v. SA Hospitality Group, LLC et al, No. 23 CIV. 3492 (PGG) (SDA), 2025 WL 3202080 (S.D.N.Y. Nov. 17, 2025) – in which plaintiff asserts claims of hostile work environment sexual harassment under the New York State and City Human Rights Laws, as well as wage & hour violations under the…
Read More EFAA Applies to Entire Case, Including Wage & Hour Claims; Motion to Compel Arbitration of FLSA & NYLL Claims ReversedIn Paige v. Garvan’s Rock and Rye, LLC, Maggie Mae’s, LLC, & Garvan McCloskey, No. 24CV3189 (DLC), 2025 WL 3201762 (S.D.N.Y. Nov. 14, 2025), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s disability discrimination claims asserted under the Americans with Disabilities Act and the New York State Human Rights Law. From…
Read More Disability Discrimination Claims, Arising From Termination Following Workers Compensation Leave, Survive Summary JudgmentIn Dranitca v. Allied Universal Sec. Services LLC, No. 150492/2025, 2025 WL 2814548 (N.Y. Sup. Ct. Sep. 26, 2025), an employment discrimination case, the court discussed and applied New York Civil Practice Law and Rules 205, which governs the timeframe in which to recommence an action in one forum after being dismissed in another. Here,…
Read More Hostile Work Environment, Retaliation, Sex Discrimination Claims Not Timely Recommenced in State Court Following Federal Court DismissalIn Wheat v. Vichie, No. 158627/2024, 2025 WL 3089438 (N.Y. Sup. Ct. Nov. 03, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s claims of discrimination asserted under the New York State and City Human Rights Laws. From the decision: The only allegations Plaintiff makes that would go towards a discrimination claim based…
Read More Display of Nazi Material Insufficient to State Discrimination Claims, Court HoldsIn Malkoukian v. Nest Seekers Intern., No. 152981/2023, 2025 WL 3080065 (N.Y. Sup. Ct. Oct. 31, 2025), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s retaliation claims under the New York State and City Human Rights Laws. From the decision: Retaliation claims under the City and State Human Rights Laws2 are reviewed under…
Read More Retaliation Claims Sufficiently Alleged; Commission Deprivation Followed Informing CEO of Hostile Work Environment