Race / Color Discrimination

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In Bates v. Leviton Manufacturing Co., Inc., No. 3:24-CV-01414, 2026 WL 2211556 (M.D. Tenn. July 31, 2026), the court, inter alia, granted defendant’s motion for summary judgment on plaintiff’s claim of race-based hostile work environment asserted under Title VII of the Civil Rights Act of 1964. Among other allegations was that another employee told plaintiff…

Read More Title VII Race-Based Hostile Work Environment Claim Dismissed; Rumor of “Slave” Comment Insufficient
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In Licea v. Illinois Cent. Ry. Co., No. 1:25-CV-08706, 2026 WL 2049497 (N.D. Ill. July 15, 2026), the court granted defendant’s motion to dismiss plaintiff’s complaint alleging employment discrimination under Title VII of the Civil Rights Act of 1964. In sum, plaintiff, a journeyman machinist, alleges that her foreman “verbally and sexually harassed” her. This…

Read More Court Dismisses Complaint Alleging Race & Sex Discrimination Under Title VII
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In Cadet v. Macy’s, Inc., No. 22-CV-7406 (VSB), 2026 WL 1998595 (S.D.N.Y. July 10, 2026), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s claims of race and national origin-based hostile work environment. As to the issue of whether the alleged conduct was sufficiently “severe” or “pervasive” under 42 USC § 1981…

Read More Race, National Origin Based Hostile Work Environment Claims Against Macy’s Survive Summary Judgment
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In Miller v. Markwayne Mullin et al, No. 1:25-CV-00703-JRR, 2026 WL 1861955 (D. Md. June 29, 2026), 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. From the decision: Here, Defendant argues all the alleged discrete discriminatory incidents…

Read More Race-Based Hostile Work Environment Claim Dismissed; Evidence, Including Monkey Emoji, Insufficient
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In Walker v. CSL Plasma, Inc., No. 6:22-CV-6413-CJS-CDH, 2026 WL 1596200 (W.D.N.Y. June 4, 2026), the court granted defendants’ motion for summary judgment on plaintiff’s claim of retaliation under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 1981, and the New York State Human Rights Law. This case is instructive as…

Read More Retaliation Claims Dismissed on Summary Judgment; Complaint Did Not Involve Accusation of Racism
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Every year on June 19th, as New York City slows down just a bit to observe Juneteenth, I find myself looking out my office window and thinking about a painful historical truth. Juneteenth commemorates June 19, 1865 – the day Union Major General Gordon Granger arrived in Galveston, Texas, to enforce the Emancipation Proclamation. What…

Read More Delayed Justice, Subtle Discrimination: Why Juneteenth Hits Differently for an NYC Employment Lawyer
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In a recent decision involving a claim of race discrimination in employment under Title VII of the Civil Rights Act of 1964, Bravo v. Dallas Indep. Sch. Dist., No. 25-10982, 2026 WL 1531713 (5th Cir. June 1, 2026), the U.S. Court of Appeals for the Fifth Circuit concluded that, notwithstanding the Supreme Court’s recent decision…

Read More Fifth Circuit Finds That SCOTUS’ Ames Decision Did Not Alter Rule Requiring Evidence of a Similarly-Situated Comparator in Title VII Race Discrimination Case
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In Thomasson v. State ex rel. Bd. of Regents of Nevada Sys. of Higher Educ., No. 3:25-CV-00611-MMD-CLB, 2026 WL 1346640 (D. Nev. May 13, 2026), the court granted defendant’s motion to dismiss plaintiff’s hostile work environment claims asserted under Title VII of the Civil Rights Act of 1964. From the decision: Defendant moves to dismiss…

Read More Title VII Hostile Work Environment Complaint Dismissed For Failure to Satisfy Rule 8’s “Short and Plain Statement” Requirement
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In White v. Harvard Security, LLC, No. 25-CV-0622, 2026 WL 1413549 (E.D. Pa. May 19, 2026), 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. From the decision: Title VII provides in relevant part that, “it shall be…

Read More Title VII Race-Based Hostile Work Environment Claim Dismissed
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In Brown v. CBS News, Inc., No. 152570/2025, 2026 WL 1348982 (N.Y. Sup. Ct. May 10, 2026), the court, inter alia, summarized and applied the law governing the geographic applicability of the New York State and City Human Rights Laws. It summarized the black-letter law as follows: The NYSHRL and NYCHRL each separately prohibit employment…

Read More Court Dismisses NYS and NYC Human Rights Law Claims on Subject Matter Jurisdiction Grounds; Relevant Conduct Occurred Outside New York
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