Title VII of the Civil Rights Act of 1964

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In Norris v. Frito-Lay, Inc., CIVIL ACTION No. 24-4023-KHV, 2025 WL 1423583 (D.Kan. May 16, 2025), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s hostile work environment sexual harassment claim, asserted under Title VII of the Civil Rights Act of 1964. From the decision: Here, plaintiff has presented evidence that (1)…

Read More Hostile Work Environment Sexual Harassment Claims Survive Summary Judgment
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In Walters v. Shintech, Inc., CIVIL ACTION NO. 23-277-JWD-SDJ, 2025 WL 918450 (M.D.La. March 26, 2025), the court, inter alia, denied defendants’ motion for summary judgment on plaintiff’s hostile work environment sexual harassment claim under Title VII of the Civil Rights Act of 1964. From the decision: In order to show a hostile work environment…

Read More Hostile Work Environment Sexual Harassment Claim Survives Summary Judgment
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In Rowe v. Poplar Grove Operations, LLC, 2025 WL 1184061 (E.D.Ark. April 23, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s race discrimination claim asserted under Title VI of the Civil Rights Act of 1964. This decision illustrates the “administrative exhaustion” requirement of Title VII, and the importance of including all pertinent…

Read More Title VII Race Discrimination Claim Dismissed as Not Administratively Exhausted
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In Sorokina v. The College of New Jersey, No. 24-1365, 2025 WL 1289148 (3d Cir. 2025), the court, inter alia, reversed a lower court’s order granting summary judgment to defendant on plaintiff’s claim of gender discrimination under Title VII of the Civil Rights Act of 1964. From the decision: Sorokina alleges that the College took…

Read More Title VII Gender Discrimination Claim, Arising From Non-Renewal of Contract, Survives Summary Judgment
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In Qamar v. Board of Trustees of Governors State University, 2025 WL 1309843 (N.D.Ill. May 6, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s national origin-based hostile work environment claim under Title VII of the Civil Rights Act of 1964. From the decision: As previewed, to bring this cause of action, the…

Read More National Origin-Based Hostile Work Environment Claim Dismissed; Alleged Harassing Emails Sent at “Odd Hours” Insufficient
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In Paul v. City of Fort Worth, Civil Action No. 4:24-cv-00913-O, 2025 WL 1287920 (N.D.Tex. May 2, 2025), the court denied defendant’s motion to dismiss plaintiff’s hostile work environment sexual harassment claim asserted under Texas law.[1]Note: I am not admitted to practice law in Texas. The court summarized the black-letter law – noting that the…

Read More Hostile Work Environment Sexual Harassment Sufficiently Alleged
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In Smith v. National Grid USA, 2:21-cv-6899 (NJC) (LGD), 2025 WL 1248676 (E.D.N.Y. April 30, 2025), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s race-based hostile work environment claims. From the decision: [T]here are numerous genuine disputes of material fact concerning Smith’s hostile work environment claims—under both the higher federal standard…

Read More Race-Based Hostile Work Environment Claims Survive Summary Judgment; Allegations Include “Shine Box” and “Monkey” Comments
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In Smart, Kathyann v. USA Labor for Hire, Inc., RC Global Energy Group, Inc., Oleg Tsimbler, No. 24-1791, 2025 WL 1217365 (2d Cir. April 28, 2025), the U.S. Court of Appeals for the Second Circuit, inter alia, affirmed the lower court’s denial of defendant’s motion for new trial or remittitur on plaintiff’s claims of hostile…

Read More 2nd Circuit Holds That Jury Properly Found Hostile Work Environment, Based on Racially Derogatory and Sexist Language,
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In Wright v. White Plains Hospital Medical Center, No. 2023-05430, 64135/19, 2025 N.Y. Slip Op. 02371, 2025 WL 1173144 (N.Y.A.D. 2 Dept., Apr. 23, 2025), the court affirmed the award of summary judgment dismissing plaintiff’s claims of pregnancy discrimination under Title VII of the Civil Rights Act of 1964 and the New York State Human Rights…

Read More Pregnancy Discrimination Claims Properly Dismissed, 2nd Department Holds
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In Browne v. New York State Department of Corrections and Community Supervision, 2025 WL 1177958 (2d Cir. April 23, 2025), the U.S. Court of Appeals for the Second Circuit affirmed the district court’s award of summary judgment to the defendant on plaintiff’s claim of a race-based hostile work environment under Title VII of the Civil…

Read More Hostile Work Environment Claim Properly Dismissed; Allegedly “Racially Offensive” Poems Insufficient
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