Race / Color Discrimination

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In Smith v. National Grid USA, 2:21-cv-6899 (NJC) (LGD), 2025 WL 1248676 (E.D.N.Y. April 30, 2025), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s race-based hostile work environment claims. From the decision: [T]here are numerous genuine disputes of material fact concerning Smith’s hostile work environment claims—under both the higher federal standard…

Read More Race-Based Hostile Work Environment Claims Survive Summary Judgment; Allegations Include “Shine Box” and “Monkey” Comments
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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 Browne v. New York State Department of Corrections and Community Supervision, 2025 WL 1177958 (2d Cir. April 23, 2025), the U.S. Court of Appeals for the Second Circuit affirmed the district court’s award of summary judgment to the defendant on plaintiff’s claim of a race-based hostile work environment under Title VII of the Civil…

Read More Hostile Work Environment Claim Properly Dismissed; Allegedly “Racially Offensive” Poems Insufficient
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In Gildyard v. Children’s Network of Southwest Florida, LLC, Case No.: 2:24-cv-702-SPC-KCD, 2025 WL 1093331 (M.D.Fla. April 10, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s race-based hostile work environment claim, on the ground that plaintiff failed to “administratively exhaust” that claim at the U.S. Equal Employment Opportunity Commission. From the decision:…

Read More Race-Based Hostile Work Environment Claim Dismissed on “Administrative Exhaustion” Grounds
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In Knox v. CRC Management Co., LLC, No. 23-121, 2025 WL 1057862 (2d Cir. April 9, 2025), the U.S. Court of Appeals for the Second Circuit, inter alia, vacated a lower court Order dismissing plaintiff’s claims, on summary judgment, of race- and national origin-based termination. From the decision: Knox alleges that Clean Rite’s decision to…

Read More Race, National Origin Discrimination Claims Survive Summary Judgment, 2nd Circuit Finds
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In Pierluissi v. City of New York, No. 153439/2023, 2025 WL 928908 (N.Y. Sup Ct, New York County Mar. 26, 2025), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s race discrimination claims under the New York State and City Human Rights Laws. From the decision: Both the NYSHRL and NYCHRL make it unlawful…

Read More Race Discrimination Claims Sufficiently Alleged; “Dumb Spic” Comments Supported Claim
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In Pierluissi v. City of New York, No. 153439/2023, 2025 WL 928908 (N.Y. Sup Ct, New York County Mar. 26, 2025), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s race & national origin-based hostile work environment claims asserted under the New York State and City Human Rights Laws. In general, plaintiff alleges that defendants…

Read More Hostile Work Environment Claims, Based on Race & National Origin, Survive Dismissal
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In Dedewo v CBS Corporation, No. 158386/22, 2024-00838, 3945, 2025 N.Y. Slip Op. 01712, 2025 WL 863866 (N.Y.A.D. 1 Dept., Mar. 20, 2025), the court affirmed the lower court’s order dismissing plaintiff’s claims for race and sex discrimination and retaliation under the New York City Human Rights Law. From the decision: To the extent plaintiff’s…

Read More Federal Court Decision Precludes NYC Human Rights Law Claims, First Department Holds
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In Alcy v. Northwell Health, Inc., 2025 WL 835647 (S.D.N.Y. March 14, 2025), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s claim of a race-based hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: With respect to Portoro, Plaintiff alleges that discriminatory…

Read More Title VII Hostile Work Environment Claim, Based on Alleged Race-Based Comment (But Not Disproportionate Workload) Survives Summary Judgment
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In Hayes v. G&E Real Estate Management Services d/b/a Newmark, 24-cv-01459 (ER), 2025 WL 769162 (S.D.N.Y. March 11, 2025), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s claim of race discrimination asserted under 42 U.S.C. § 1981. Plaintiff asserted that she suffered discrimination in the form of various “adverse employment actions” – including…

Read More Race Discrimination Claim Survives Dismissal; Under Muldrow Standard, Negative Performance Review Was an “Adverse Employment Action”
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