Retaliation

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In Rosenson v. Bloomfield, Civil Action No. 24-1365 (SLS), 2025 WL 958254 (D.D.C. March 31, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s retaliatory hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: To prevail on a retaliatory hostile-work-environment claim, “a plaintiff must…

Read More Hostile Work Environment Claim Dismissed; Repeated Criticism and Other Actions Held Insufficiently Severe or Pervasive
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In Swinburne v. City of New York, No. 153793/2024, 2025 WL 990587 (N.Y. Sup Ct, New York County Mar. 28, 2025), the court denied defendant’s motion to dismiss plaintiff’s retaliation claim asserted under the New York City Human Rights Law. From the decision: Under [NYCHRL], it is unlawful to retaliate against an employee for opposing…

Read More Retaliation Claim Sufficiently Alleged; Transfer/Demotion Followed Request for Vaccine Exemption
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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 Matter of Pedro Osorio v. New York State Division of Human Rights and McAlpin Industries, Inc., No. 201, 24-01441, 2025 WL 877798 (N.Y.A.D. 4 Dept., Mar. 21, 2025), the court, inter alia, held that petitioner’s retaliation claim was properly dismissed by the State Division of Human Rights’ determination that petitioner was not subjected to…

Read More Coughing/Sneezing on Supervisor Was Legitimate Reason For Termination; Hostile Work Environment and Retaliation Claims Properly Dismissed
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In Walls v. City of New York, No. 156492/2024, 2025 WL 697108 (N.Y. Sup Ct, New York County Mar. 04, 2025), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s hostile work environment claim on statute of limitations grounds. In doing so, the court applied the “continuing violation doctrine”: Defendants argue that Plaintiff’s claims…

Read More Applying “Continuing Violation Doctrine”, Court Rejects Statute of Limitations Challenge to Hostile Work Environment Claims
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In Schoenadel v. YouGov America Inc., 22-cv-10236 (AS), 2025 WL 371089 (S.D.N.Y. Feb. 3, 2025), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s retaliation claims under Title VII of the Civil Rights Act of 1964, the New York State Human Rights Law, and the New York City Human Rights Law. Here held the…

Read More Retaliation Claims Survive Summary Judgment; Adverse Actions Included Exclusion From Meetings
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In Montes v. City of New York, No. 158272/2023, 2025 WL 290440 (N.Y. Sup Ct, New York County Jan. 21, 2025), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s retaliation claim asserted under the New York City Human Rights Law. From the decision: “Under [NYCHRL], it is unlawful to retaliate against an employee…

Read More Retaliation Claim Sufficiently Alleged; Threats of Termination Followed Request for Disability Accommodation
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In James v. Disney Studios Content, No. 159201/2022, 2025 WL 257207 (N.Y. Sup Ct, New York County Jan. 21, 2025), the court denied defendant’s motion to dismiss plaintiff’s claim of retaliation under the New York State and City Human Rights Laws, on the ground that the court lacks subject matter jurisdiction pursuant to CPLR 3211(a)(2).…

Read More Disney Actor’s Discrimination Claim Survives Dismissal; Court Explains NYS and NYC Human Rights Laws’ “Impact Test”
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In Berrios v. Rose Associates, Inc., No. 652417/2021, 2024 WL 5182598 (N.Y. Sup Ct, New York County Dec. 19, 2024), a housing discrimination case, the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s claims of retaliation asserted under the New York State and City Human Rights Laws. From the decision: To prove…

Read More Retaliation Claims, Based on Issues With Repair and Service Following Complaint About Super’s Alleged Discriminatory Comment, Survives Summary Judgment
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In Qorrolli v. Metropolitan Dental Associates, 2024 WL 5194887 (2d Cir. Dec. 23, 2024), the U.S. Court of Appeals for the Second Circuit, inter alia, affirmed the lower court’s award of summary judgment to defendant on plaintiff’s claims of retaliation, on the ground that plaintiff did not engage in “protected activity.” From the decision: Finally,…

Read More Rejection of Sexual Advances Did Not Constitute “Protected Activity” For Retaliation Claim, 2nd Circuit Holds
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