Title VII of the Civil Rights Act of 1964

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In Erazo v. IGH Restoration LLC, 23 Civ. 3982 (DEH), 2025 WL 2298712 (S.D.N.Y. Aug. 8, 2025), concerning alleged sexual harassment, the court denied defendants’ motion for summary judgment on plaintiff’s claims under Title VII of the Civil Rights Act of 1964. Specifically, this decision discusses the issue of whether a defendant is considered an…

Read More Sexual Harassment Plaintiff Presents Sufficient Evidence to Create Triable Issue as to Whether Defendant is a Title VII “Employer”
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In Choudhury v. Northwell Health, Inc., 23-cv-01406 (NCM) (SIL), 2025 WL 2300220 (E.D.N.Y. Aug. 8, 2025), the court, inter alia, denied defendants’ motion for summary judgment on plaintiff’s claims of race, religion, and national origin based hostile work environment asserted under the New York State Human Rights Law. Notably, the court initially granted defendants’ motion…

Read More Hostile Work Environment Claims Survive Summary Judgment Under NYS Human Rights Law (But Not Title VII)
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Being fired is an incredibly stressful and confusing experience, especially when you believe the termination was unfair or illegal. It’s a moment when emotions run high, and it can be difficult to think clearly. However, the actions you take (or don’t take) immediately following your termination can significantly impact your ability to pursue a legal…

Read More A Practical Guide for NYC Workers: What to Do (and Not to Do) After Being Fired Unfairly
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In Parks v. Nordson Medical of NH Inc., 2025 WL 2177177 (E.D.Tenn. July 31, 2025), the court held that plaintiff’s allegations did not plausibly state a claim for sexual harassment, and therefore that the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 did not apply. From the decision: A court determines…

Read More Sexual Harassment Insufficiently Alleged; “Vulgar” Conduct Not Actionable
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In Kekovic v. Titan Motor Group LLC et al, 22-CV-2142 (MKB), 2025 WL 2173651 (E.D.N.Y. July 31 2025), the court, inter alia, denied defendants’ motion for summary judgment as to plaintiff’s claims of a race-based hostile work environment claims asserted under Title VII of the Civil Rights Act of 1964, Section 1981, and the New…

Read More Race-Based Hostile Work Environment Claims Survive Summary Judgment; Evidence Included Use of the “N-Word” at a Work Dinner
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In Thomas v. Poo Bah Enterprises, Inc., d/b/a Rick’s Cabaret Chicago, No. 25-cv-77, 2025 WL 2084159 (N.D.Ill. July 24, 2025), the court explained and clarified the pleading standard is contemplated by the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 in the context of a sexual harassment dispute. Here, plaintiff –…

Read More Court Adopts NY Federal Court’s Interpretation of EFAA in Retaliation/Sexual Harassment Case
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In McConkey v. The Churchill School and Center, 24-cv-6091 (LJL), 2025 WL 2062195 (S.D.N.Y. July 23, 2025), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s claim of sexual orientation discrimination asserted in violation of Title VII of the Civil Rights Act of 1964. From the decision: Given Plaintiff’s minimal burden at the motion…

Read More Sexual Orientation Discrimination Claims Survive Dismissal
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In Tracey Ellis, Jamar Mattox, and Eric King v. Oak Lawn Hyundai, Inc., d/b/a Happy Hyundai and Delila Dedic, 2025 WL 1940375 (N.D.Ill. July 15, 2025), the court, inter alia, denied defendant’s motion to dismiss a plaintiff’s race-based hostile work environment claim. From the decision: In Count II, King brings a claim for hostile work…

Read More Race-Based Hostile Work Environment Sufficiently Alleged, Even Though Some Conduct Was Not Directed at Plaintiff
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In Spann v. FedEx Freight, Inc., 2025 WL 1938355 (5th Cir. July 15, 2025), the U.S. Court of Appeals for the Fifth Circuit, inter alia, affirmed the lower court’s grant of summary judgment on plaintiff’s race- and gender-based hostile work environment claims. From the decision: A hostile work environment claim is composed of a series…

Read More Race, Gender Hostile Work Environment Claims Properly Dismissed: Fifth Circuit
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In McCarty v. City of Alexandria, 2025 WL 1899987 (E.D.Va. July 9, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s race-based hostile work environment claim. From the decision: The essence of Plaintiff’s race-based hostile work environment claim is that she was generally treated less favorably than her white co-workers, could not access…

Read More Conduct, While “Professionally Frustrating”, Did Not Amount to Race-Based Hostile Work Environment
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