NYC Human Rights Law Geographic Applicability

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In Brown v. CBS News, Inc., No. 152570/2025, 2026 WL 1348982 (N.Y. Sup. Ct. May 10, 2026), the court, inter alia, summarized and applied the law governing the geographic applicability of the New York State and City Human Rights Laws. It summarized the black-letter law as follows: The NYSHRL and NYCHRL each separately prohibit employment…

Read More Court Dismisses NYS and NYC Human Rights Law Claims on Subject Matter Jurisdiction Grounds; Relevant Conduct Occurred Outside New York
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In Dunphy v. Giuliani, No. 650033/2023, 2026 WL 907841 (N.Y. Sup. Ct. Mar. 30, 2026), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s hostile work environment claims under the New York State and City Human Rights Laws on the grounds of jurisdiction (lack of connection to New York City) and timeliness. From the…

Read More Sexual Harassment, Hostile Work Environment Claims Sufficiently Alleged Against Giuliani, Court Holds
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In Clarke v. SOC, LLC, No. 527239/24, 2025 WL 2614623 (N.Y. Sup Ct, Kings County Sep. 09, 2025), the court, inter alia, dismissed plaintiff’s claims under the New York State and City Human Rights Law, since the alleged conduct did not occur in New York. From the decision: Both the NYSHRL and NYCHRL make it…

Read More NYS and NYC Human Rights Law Discrimination Claims Dismissed; Geographic Requirement Not Satisfied
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In Huaman v. United Airlines, Inc., No. 160784/2023, 2025 WL 1158984 (N.Y. Sup Ct, New York County Apr. 21, 2025), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s complaint asserting employment discrimination under the New York State and City Human Rights Laws. From the decision: Defendants’ motion to dismiss pursuant to CPLR 3211(a)(7)…

Read More Motion to Dismiss NYSHRL & NYCHRL Discrimination Claims Denied; “Impact” Test Satisfied
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In James v. Disney Studios Content, No. 159201/2022, 2025 WL 257207 (N.Y. Sup Ct, New York County Jan. 21, 2025), the court denied defendant’s motion to dismiss plaintiff’s claim of retaliation under the New York State and City Human Rights Laws, on the ground that the court lacks subject matter jurisdiction pursuant to CPLR 3211(a)(2).…

Read More Disney Actor’s Discrimination Claim Survives Dismissal; Court Explains NYS and NYC Human Rights Laws’ “Impact Test”
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In Diaz-Roa v. Hermes Law, P.C. et al, 24-cv-2105 (LJL), 2024 WL 4866450 (SDNY Nov. 21, 2024), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s claims of sexual harassment asserted under the New York State and City Human Rights Laws. From the decision: The complaint contains several paragraphs of conduct alleged to constitute…

Read More Sexual Harassment Claims Sufficiently Alleged; Allegations Included Focus on Plaintiff’s, But Not Male Employees’, Appearances
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In Murray v. Brag Sales Inc. d/b/a Uneeda Enterprises et al, 2024 WL 4635479 (S.D.N.Y. Oct. 31, 2024), the court denied plaintiff’s motion for reconsideration of the dismissal of his claim of employment discrimination asserted under the New York City Human Rights Law. This decision is instructive on the geographic reach of that statute. From…

Read More Court Upholds Dismissal of NYCHRL Discrimination Claim; Plaintiff Worked Outside NYC
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In Syeed v Bloomberg L.P., No. 20, 2024 N.Y. Slip Op. 01330, 2024 WL 1097279 (N.Y. Ct. App. Mar. 14, 2024), the New York Court of Appeals, answered the following certified question from the U.S. Court of Appeals for the Second Circuit: Whether a nonresident plaintiff not yet employed in New York City or State…

Read More NY Court of Appeals Issues Worker-Friendly Decision as to NYC Human Rights Law’s “Impact” Requirement
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In Mitura v. Finco Services, Inc. et al, 23-CV-2879 (VEC), 2024 WL 232323 (S.D.N.Y. Jan. 22, 2024), the court, inter alia, denied the defendant’s motion to compel arbitration of plaintiff’s sexual harassment claims. In sum, the court held that arbitration was barred by the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of…

Read More Arbitration of Sexual Harassment Claims Denied, Pursuant to the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021
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In Syeed v. Bloomberg L.P., 2023 WL 350565 (2d Cir. Jan. 23, 2023), the court addressed, and certified to the New York Court of Appeals, the following question: Whether a nonresident plaintiff not yet employed in New York City or State satisfies the NYCHRL or NYSHRL impact requirement if the plaintiff pleads and later proves…

Read More Second Circuit Certifies Question of Geographic Applicability of NYS and NYC Human Rights Laws to NY Court of Appeals
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