Race / Color Discrimination

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In Snowden v. County of Sullivan, 22 CV 514 (VB), 2024 WL 4882700 (S.D.N.Y. Nov. 25, 2024), the court denied defendant’s motion for summary judgment on plaintiff’s claim of race discrimination asserted under Title VII of the Civil Rights Act of 1964. After summarizing the black-letter law, including the McDonnell Douglas burden-shifting framework applicable to…

Read More Race Discrimination Claim, Arising From Suspension, Survives Summary Judgment
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In U.S. Equal Employment Opportunity Commission v. Council for Advancement of Social Services and Education, 2024 WL 4479882 (W.D.La. Oct. 10, 2024), the court, inter alia, held that the plaintiff sufficiently alleged a claim of race-based employment discrimination under Title VII of the Civil Rights Act of 1964. From the decision: As stated above, the…

Read More Race-Based Discrimination Claim Sufficiently Alleged; Contentions Included Replacement by White Employee
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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 ACLU
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In 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 Columbia
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In 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 Colleagues
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In 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 Class
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In 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” Utterance
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In 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 Claim
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In 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 Laws
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In 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 Holds
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