Title VII of the Civil Rights Act of 1964

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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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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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