In Brown v. Montefiore Health System, Inc., No. 24-3078-cv, 2025 WL 2985389 (2d Cir. Oct. 23, 2025), the U.S. Court of Appeals for the Second Circuit held that plaintiff indeed stated a claim for a race-based hostile work environment claim under Title VII of the Civil Rights Act of 1964 and the New York State…
Read More Race-Based Hostile Work Environment Plausibly AllegedIn Brown v. Montefiore Health System, Inc., No. 24-3078-cv, 2025 WL 2985389 (2d Cir. Oct. 23, 2025), the U.S. Court of Appeals for the Second Circuit held that plaintiff indeed stated a claim for a race-based discrimination (termination) claim under Title VII of the Civil Rights Act of 1964 and the New York State Human…
Read More 2nd Circuit Vacates Lower Court Decision; Race-Based Termination Claim Survives DismissalIn Laporte, Jose v. Sullivan, Brian, 1:24-cv-1124 (ECC/DJS), 2025 WL 2645531 (N.D.N.Y. Sept. 15, 2025), the court denied defendant’s motion to dismiss plaintiff’s – a dark-skinned Hispanic man – claim of race/national origin discrimination in violation of the Equal Protection Clause of the Fourteenth Amendment and 42 U.S.C § 1983. From the decision: Plaintiff argues…
Read More Upstate Hispanic Correction Officer Sufficiently Alleges Race & National Origin DiscriminationIn Garcia v. Westhampton Primary Care, 2:23-cv-4319 (NJC) (ST), 2025 WL 2494357 (E.D.N.Y. Aug. 30, 2025), the court, inter alia, held that plaintiff plausibly alleged claims of hostile work environment under Title VII of the Civil Rights Act of 1964 and the New York State Human Rights Law. The court summarized, and applied, the law…
Read More Hostile Work Environment, Retaliatory Hostile Work Environment Claims Survive DismissalIn Shimeles v. Fairfax County School Board, Civil Action No. 1:24-cv-474 (RDA/IDD), 2025 WL 2375203 (E.D.Va. Aug. 14, 2025), the court, inter alia, held that plaintiff sufficiently alleged a racially-hostile work environment, in violation of Title VII of the Civil Rights Act of 1964. From the decision: Unwelcome conduct rises to the level of being…
Read More Race-Based Hostile Work Environment Sufficiently Alleged; Court Cites Claimed Threat of Hanging by NooseIn Tracey Ellis, Jamar Mattox, and Eric King v. Oak Lawn Hyundai, Inc., d/b/a Happy Hyundai and Delila Dedic, 2025 WL 1940375 (N.D.Ill. July 15, 2025), the court, inter alia, denied defendant’s motion to dismiss a plaintiff’s race-based hostile work environment claim. From the decision: In Count II, King brings a claim for hostile work…
Read More Race-Based Hostile Work Environment Sufficiently Alleged, Even Though Some Conduct Was Not Directed at PlaintiffIn Edwards, Robert v. JBS Souderton, Inc., CIVIL ACTION No. 23-1789, 2025 WL 1888204 (E.D.Pa. July 8, 2025), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s race-based hostile work environment claim, based on the alleged use of a racial slur, in violation of 42 U.S.C. § 1981. From the decision: To state a…
Read More Race-Based Hostile Work Environment Claim, Based on Alleged Use of “Moyo” Slur, Survives Motion to DismissIn Vargas v. City of New York, No. 151379/2024, 2025 WL 1797597 (N.Y. Sup Ct, New York County June 30, 2025), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s claims of race- and gender-based discrimination and hostile work environment claims asserted under the New York State and City Human Rights Laws. From the…
Read More Race, Sex Discrimination & Hostile Work Environment Claims Sufficiently Alleged Against City of New YorkIn Ruiz v. Credit Agricole Corporate and Investment Bank, Anthony Botting, 2025 WL 1642406 (S.D.N.Y. June 10, 2025), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s race-based hostile work environment claim asserted under the New York City Human Rights Law. From the decision: I turn next to Plaintiff’s claim under the NYCHRL that…
Read More Race-Based Hostile Work Environment Claim, Asserted Under the NYC Human Rights Law, Survives Dismissal
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In Flanagan et al v. Girl Scouts of Suffolk County, Inc. et al, 23-7900-cv, 2025 WL 1501751 (2d Cir. May 27, 2025), the court, inter alia, held that plaintiff plausibly alleged race discrimination under 42 U.S.C. § 1981 and the New York State Human Rights Law (NYSHRL), and vacated a lower court order holding otherwise.…
Read More Race Discrimination Claims Plausibly Alleged; 2nd Circuit Vacates Dismissal