Title VII of the Civil Rights Act of 1964

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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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In Noh v. Admarketplace, Inc., 24 Civ. 2107 (ER), 2025 WL 965882 (S.D.N.Y. March 28, 2025), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s sex- and race-based hostile work environment claims asserted under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 1981, and the New York State and City…

Read More Hostile Work Environment Claim, Based on Race and Sex, Survive Dismissal
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In Huber v. TIAA, 2025 WL 1139131 (W.D.Va. April 17, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s hostile work environment claim in violation of Title VII of the Civil Rights Act of 1964. In sum, plaintiff alleged that defendant engaged in religious discrimination by failing to accommodate her request for a…

Read More Title VII Religion-Based Hostile Work Environment Claim Dismissed
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In Johnson v. 212 Fremont Sandusky Wine & Spirit, LLC, 2025 WL 843390(N.D.Ohio March 18, 2025), the court ruled on defendant’s motion for summary judgment on plaintiffs’ claims of hostile work environment sexual harassment asserted under Title VII of the Civil Rights Act of 1964 (as well as Ohio stae law). As to two plaintiffs,…

Read More Hostile Work Environment Sexual Harassment Claim Survives Summary Judgment; Alleged Harassment Was “Direct and Physical”
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In Beatty v. NYC District Council of Carpenters and Joiners of America, 1:23-cv-02126 (ALC) (SN), 2025 WL 963307 (S.D.N.Y. March 31, 2025), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s sex-based hostile work environment claims asserted under Title VII of the Civil Rights Act of 1964, the New York State Human…

Read More Sex-Based Hostile Work Environment Claims Survive Summary Judgment; Evidence Included Appearance-Related Jokes and Comments
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In Kozak v. Office Depot, Inc., 2025 WL 898979 (W.D.N.Y. March 25, 2025), the court, inter alia, held that defendant’s motion for summary judgment should have been denied – and thus disagreed with the Magistrate Judge’s decision to the contrary – as to plaintiff’s sex discrimination claim asserted under Title VII of the Civil Rights…

Read More Title VII Sex Discrimination Claim Survives Summary Judgment; Sexual Harassment Claim Was “Inextricably Intertwined” With Termination Decision
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In Hamilton v. Siemens Healthcare Diagnostics, Inc., 2025 WL 863572 (S.D.N.Y. March 18, 2025), the court, inter alia, dismissed plaintiff’s hostile work environment claims. After summarizing the black-letter law, the court applied it to the facts as follows: Plaintiff alleges that he experienced “a pattern of activity aimed at bringing about [his] resignation.” (Am. Compl.…

Read More Hostile Work Environment Claims Dismissed; Allegations Failed to Rise to the Level of “Severe or Pervasive”; Causation Not Shown
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In Alcy v. Northwell Health, Inc., 2025 WL 835647 (S.D.N.Y. March 14, 2025), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s claim of a race-based hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: With respect to Portoro, Plaintiff alleges that discriminatory…

Read More Title VII Hostile Work Environment Claim, Based on Alleged Race-Based Comment (But Not Disproportionate Workload) Survives Summary Judgment
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In Shelton v. University Healthcare System, L.C., 2025 WL 816293 (E.D.La. March 14, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. This decision is instructive on Title VII’s “severe or pervasive” standard for assessing such claims. From…

Read More Title VII Hostile Work Environment Claim Dismissed; Additional Workload Did Not Amount to “Severe or Pervasive” Harassment
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In Little v. R & L Carriers, Inc. et al, 3:24-CV-836 (OAW), 2025 WL 744276 (D.Conn. March 9, 2025), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s race-based hostile work environment claim under Title VII of the Civil Rights Act of 1964. From the decision: To establish a hostile work environment claim under…

Read More Title VII Race-Based Hostile Work Environment Claim Survives Dismissal
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