In Jackson, Robert v. American Civil Liberties Union, Inc. et al, 21-CV-5037 (JPO), 2024 WL 4766983 (S.D.N.Y. Nov. 13, 2024), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s claims of race discrimination under Title VII of the Civil Rights Act of 1964 and 42 U.S.C. § 1981. After summarizing the McDonnell…
Read More Race Discrimination Claims Survive Summary Judgment Against ACLUIn Robinson v. District of Columbia, 2024 WL 4722157 (D.D.C. Nov. 8, 2024), the court, inter alia, dismissed plaintiff’s claim of race-based hostile work environment asserted under Title VII of the Civil Rights Act of 1964. After explaining that plaintiff failed to plead a timely hostile work environment claim, the court continued: Plaintiff’s hostile work…
Read More Title VII Race-Based Hostile Work Environment Claim Dismissed Against the District of ColumbiaIn Byrd v. Becerra, Civil Action No. 22-3746 (TSC), 2024 WL 4591438 (D.D.C. Oct. 28, 2024), the court, inter alia, held that plaintiff sufficiently alleged employment discrimination under Title VII of the Civil Rights Act of 1964. As to the “inference of discrimination” element, the court explained: Plaintiff has also pleaded an inference of discrimination…
Read More Title VII Race Discrimination Claim Survives Dismissal; Allegations Included Reassignment of Work to White ColleaguesIn Munck v. Simons Foundation, 2024 WL 4307776 (S.D.N.Y. Sept. 26, 2024), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s race-based hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. After determining that plaintiff did not allege any timely acts to “anchor” earlier related acts to enable…
Read More Hostile Work Environment Claim Dismissed; Only Timely Alleged Act Was Termination of Employee Outside Plaintiff’s Protected ClassIn McBride v. C&C Apartment Management LLC et al, 21 Civ. 02989 (DEH), 2024 WL 4403701 (S.D.N.Y. Oct. 1, 2024), the court, inter alia, granted defendant’s motion for summary judgment dismissing plaintiff’s race, national origin, and religion-based hostile work environment claims asserted under Title VII of the Civil Rights Act of 1964 and 42 U.S.C.…
Read More Race-Based Hostile Work Environment Claim Dismissed; Corrective Action Followed Alleged “N-Word” UtteranceIn Uzomechina v. Episcopal Diocese of New Jersey, 2024 WL 4336974 (D.N.J. Sept. 26, 2024), the court applied the “ministerial exception” to dismiss plaintiff’s race-based discrimination claim asserted under 42 U.S.C. § 1981. From the decision: With respect to Plaintiff’s sole federal claim under Section 1981, the Diocese Defendants argue that the “[ministerial] exception operates…
Read More Applying “Ministerial Exception,” Court Dismisses Plaintiff’s Race Discrimination ClaimIn Reach v. Healthfirst, Inc., 23-CV-8085 (JPO), 2024 WL 4493769 (S.D.N.Y. Oct. 15, 2024), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s hostile work environment claims asserted under the New York State and City Human Rights Laws.[1]The court initially found that plaintiff failed to sufficiently allege claims under federal law. From the decision:…
Read More Race-Based Hostile Work Environment Claims Sufficiently Alleged Under NYS and NYC Human Rights LawsIn Holmes v. Lloyd J. Austin, III, Civil Action No. 23-2415 (LLA), 2024 WL 4345829 (D.D.C. Sept. 30, 2024), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s race-based hostile work environment claim under Title VII of the Civil Rights Act of 1964. From the decision: Ms. Holmes alleges that Major Sinclair perpetuated a…
Read More “Monkey” Comment Gives Rise to Actionable Race-Based Hostile Work Environment Claim, Court HoldsIn King v. UA Local 91 et al, 2024 WL 4437132 (N.D.Ala. Oct. 7, 2024), the court, inter alia, granted defendants’ motion for summary judgment on plaintiff’s race-based hostile work environment claims under Title VII of the Civil Rights Act of 1964 and 42 U.S.C. § 1981. From the decision: The only evidence Plaintiffs cite…
Read More Confederate Flag Did Not Give Rise to Hostile Work Environment, Court HoldsIn Luo v. AIK Renovation Inc. et al, 2023-cv-5878 (LJL), 24 WL 4444283 (S.D.N.Y. Oct. 8, 2024), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s hostile work environment claim asserted under the New York State and City Human Rights Laws. From the decision: Under the NYCHRL, the conduct at issue must…
Read More Race/National Origin (Chinese) Hostile Work Environment Claims Survive Summary Judgment, Court Rules