In Livingston-Willis v. Iberia Comprehensive Community Health Center Inc. et al, No. 6:25-CV-00954, 2025 WL 3457935 (W.D. La. Nov. 13, 2025), the court, inter alia, held that plaintiff failed to state a hostile work environment claim under Title VII of the Civil Rights Act of 1964. From the decision: In order to establish a hostile…
Read More Hostile Work Environment Claim Not Stated; Only “Passive” Conduct AllegedIn Dorsey v. Iberia Comprehensive Community Health Center Inc. et al, No. 6:25-CV-00952, 2025 WL 3263883 (W.D. La. Nov. 6, 2025), the court held that plaintiff failed to state a sex-based hostile work environment claim under Title VII of the Civil Rights Act of 1964. From the decision: In order to establish a hostile working…
Read More Hostile Work Environment Claim Dismissed; “Disrespect” InsufficientIn Elliff v. City of Mesa, No. CV-25-01146-PHX-JJT, 2025 WL 3237480 (D. Ariz. Nov. 20, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s claim of sex discrimination under Title VII of the Civil Rights Act of 1964. From the decision: Title VII prohibits employers covered by the Act from discriminating against an…
Read More Title VII Sex-Based Hostile Work Environment Claim, Based on Conduct Towards Non-Employee SpouseIn Mera et al v. SA Hospitality Group, LLC et al, No. 23 CIV. 3492 (PGG) (SDA), 2025 WL 3202080 (S.D.N.Y. Nov. 17, 2025) – in which plaintiff asserts claims of hostile work environment sexual harassment under the New York State and City Human Rights Laws, as well as wage & hour violations under the…
Read More EFAA Applies to Entire Case, Including Wage & Hour Claims; Motion to Compel Arbitration of FLSA & NYLL Claims ReversedIn Dranitca v. Allied Universal Sec. Services LLC, No. 150492/2025, 2025 WL 2814548 (N.Y. Sup. Ct. Sep. 26, 2025), an employment discrimination case, the court discussed and applied New York Civil Practice Law and Rules 205, which governs the timeframe in which to recommence an action in one forum after being dismissed in another. Here,…
Read More Hostile Work Environment, Retaliation, Sex Discrimination Claims Not Timely Recommenced in State Court Following Federal Court DismissalIn Lia-Basile v. the County of Albany et al, No. 1:25-CV-0291 (GTS/MJK), 2025 WL 3019150 (N.D.N.Y. Oct. 29, 2025), the court, inter alia, granted defendants’ motion to dismiss plaintiff’s claims of sex/gender discrimination asserted under Title VII of the Civil Rights Act of 1964, on the ground that she failed to exhaust her administrative remedies…
Read More Title VII Sex/Gender Discrimination Claims Dismissed For Failure to Exhaust Administrative Remedies at the EEOCIn Thompson v. Douglas A. Collins, Secretary of Veterans Affairs, 22-CV-4732 (EK)(SDE), 2025 WL 2962734 (E.D.N.Y. Oct. 2, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s gender-based discrimination (failure to promote, transfer) claims asserted under Title VII of the Civil Rights Act of 1964. From the decision: On a failure-to-promote claim, “it…
Read More Title VII Sex Discrimination (Failure to Promote, Transfer) Claims DismissedIn Rachwalski v. Pamela Bondi et al, 2025 WL 2432162 (S.D.Ind. Aug. 21, 2025), the court, inter alia, granted defendants’ motion for summary judgment on plaintiff’s sex-based hostile work environment claim asserted under Title VII of the Civil Right Act of 1964. From the decision: Title VII prohibits employers from discriminating against employees based on…
Read More Sex-Based Hostile Work Environment Claim Dismissed; Alleged Conduct Was Not Objectively Offensive Nor Severe or PervasiveIn Udoh v. NYC Dept. of Probation, 24-cv-03982 (ER), 2025 WL 219961 (S.D.N.Y. Aug. 1, 2025), the court dismissed plaintiff’s sex discrimination claim asserted under Title VII of the Civil Rights Act of 1964, because plaintiff did not “administratively exhaust” that claim before the U.S. Equal Employment Opportunity Commission. From the decision: The Court finds…
Read More Court, Applying the “Administrative Exhaustion” Doctrine, Dismisses Title VII Sex Discrimination ClaimIn Margarita v Mountain Time Health, LLC, No. 2023-07450, 527470/22, 2025 N.Y. Slip Op. 04089, 2025 WL 1888542 (N.Y.A.D. 2 Dept., July 09, 2025), the New York Appellate Division, Second Department, affirmed the lower court’s order granting defendants’ motion to dismiss plaintiff’s gender-based discrimination under the New York State and Human Rights Laws. From the…
Read More Citing Other Employees’ Contemporaneous Termination, 2nd Dept. Upholds Dismissal of Employment Discrimination Claims