NYC Human Rights Law Geographic Applicability

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In Shiber v. Centerview Partners LLC, 21 Civ. 3649, 2022 WL 1173433 (S.D.N.Y. April 20, 2022), the court dismissed plaintiff’s disability discrimination claims asserted under the New York State and New York City Human Rights Laws. This decision is instructive as to how courts apply those statutes’ geographic (“impact”) test in the increasingly-prevalent factual context…

Read More NYCHRL Disability Discrimination Claim Dismissed; Geographic “Impact” Requirement Not Satisfied
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In Jarusauskaite v. Almod Diamonds, Ltd., et al., 2020-04756, 2021 WL 4734048 (N.Y.A.D. 1 Dept. Oct. 12, 2021), the court held that plaintiff’s claims under the New York State and City Human Rights Laws because of an insufficient connection to New York. From the decision: Supreme Court lacks subject matter jurisdiction over the Human Rights…

Read More NY Human Rights Law Discrimination Claims Dismissed; NY Impact Lacking
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In Hay v. New York Media LLC, 20-CV-6135, 2021 WL 2741653 (S.D.N.Y. July 1, 2021), the court discussed and applied the geographic limitations of the New York City Human Rights Law. The plaintiff in this case is Bruce Hay, a professor at Harvard Law School. He brought this lawsuit against the author (Kera Bolonik) and…

Read More MA Professor’s NYC Human Rights Law Sexual Harassment Claim Lacked Geographic Connection to NYC; Leave to Amend Complaint Denied as Futile
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In Kraiem v. Jonestrading Institutional Services LLC, No. 19-5160, 2021 WL 2134818 (S.D.N.Y. May 26, 2021), the court, inter alia, granted plaintiff’s motion for leave to amend her First Amended Complaint to include an “aiding and abetting” theory of liability against one individual defendant (Mazzullo). From the decision: Plaintiff sufficiently alleges that Mazzullo aided and…

Read More Aiding-and-Abetting Claim Against Individual Defendant Sufficiently Alleged in Hostile Work Environment Sexual Harassment Case
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In Pakniat v. Moor, 2021 NY Slip Op 01856 (App. Div. 1st Dept. march 25, 2021), the court affirmed the dismissal of plaintiff’s sexual harassment and retaliation claims under the New York State and City Human Rights Laws, on the ground that the court lacked subject matter jurisdiction over those claims. Here, the plaintiff was…

Read More Sexual Harassment & Retaliation Claims Dismissed; Court Lacked Subject Matter Jurisdiction Over NY State and City Human Rights Law Claims Asserted by Montreal-Based Plaintiff
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In Bush v. Alliant Content, LLC, No. 151495/2020, 2021 WL 1204987 (N.Y. Sup Ct, New York County Mar. 29, 2021), the court dismissed, with prejudice, plaintiff’s claim of employment discrimination under the New York City Human Rights Law (NYCHRL). While that statute is comparatively broader than its federal and state counterparts, it will not apply…

Read More Finding Insufficient Connection to New York City, Court Strikes NYC Human Rights Law Claim From Employment Discrimination Complaint
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In Ware v. L-3 Vertex Aerospace, LLC, 2020 WL 6494823 (2d Cir. Nov. 5, 2020) (Summary Order), the court, inter alia, affirmed the dismissal of plaintiff’s employment discrimination claims asserted under the New York State and City Human Rights Laws on geographic grounds. From the Order: Ware was a resident of Jacksonville, Florida during his…

Read More Afghanistan-Based Employee’s New York State and City Law Discrimination Claims Properly Dismissed
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In Pakniat v Moor et al, No. 160019/2019, 2020 WL 2198218 (N.Y. Sup Ct, New York County May 04, 2020), a sexual harassment case, the court held that the plaintiff did not satisfy the geographical requirements of the New York State and City Human Rights Laws. The facts, briefly: [P]laintiff lived and worked in Canada…

Read More Sexual Harassment Claims Dismissed; Geographical Requirements of NY State and City Human Rights Laws Not Satisfied
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In Wang v. Air China Limited and LB Oceanfront Corp., 17-CV-6662, 2020 WL 1140458 (E.D.N.Y. March 9, 2020), the court, inter alia, denied defendants’ motion for summary judgment on plaintiff’s sexual harassment claim. From the decision: After assessing the totality of the alleged conduct, the relevant factors, and the Second Circuit’s caution against “setting the…

Read More Sexual Harassment Claim Survives Summary Judgment
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In Mejia v. White Plains Self Storage Corp., 2020 WL 247995 (S.D.N.Y. Jan. 16, 2020), the court, inter alia, dismissed plaintiff’s employment discrimination claim asserted under the New York City Human Rights Law. The court based its decision as to that claim on the NYCHRL’s limited geographic applicability. The court summarized the law as follows:…

Read More NYC Human Rights Law’s Geographic Limitations Explained and Applied
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