Title VII of the Civil Rights Act of 1964

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In Karupaiyan v. Experis US Inc., ManpowerGroup US Inc et al, 2025 WL 615179 (2d Cir. 2025), the U.S. Court of Appeals for the Second Circuit affirmed the lower court’s dismissal of plaintiff’s various discrimination claims, on the ground that plaintiff was an independent contractor, not an “employee.” From the decision: The district court also…

Read More Discrimination Claims Dismissed; Plaintiff Sought Employment as an “Independent Contractor”, Not An “Employee”
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In Delancey v. Justin Wells, Fox Corporation, and Fox News Network, LLC, 23 Civ. 10357 (AT), 2025 WL 579971 (S.D.N.Y. Feb. 21, 2025), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s claim of hostile work environment sexual harassment asserted under the New York State Human Rights Law (which, explained the court, employs the…

Read More Hostile Work Environment Sexual Harassment Claim Sufficiently Alleged Against Fox
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In White v. Roosevelt Union Free School District Board of Education, 15-CV-1035(JS)(JMW), 2025 WL 552744 (E.D.N.Y. Feb. 19, 2025), the court, inter alia, granted defendant’s motion for summary judgment on the (Caucasian) plaintiff’s claim of race-based hostile work environment asserted under Title VII of the Civil Rights Act of 1964. After summarizing the black-letter law,…

Read More Race-Based Hostile Work Environment Claim Dismissed; “Whitey”, “Asshole”, etc Comments Insufficient
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In a recent case, Glapion v. Saks Fifth Avenue, LLC, No. 24-2232, 2025 WL 506649 (E.D.La. Feb. 14, 2025), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s sex-based hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: To state a claim for hostile work…

Read More Sex-Based Hostile Work Environment Claim, Based in Part on Alleged Harassment by Customer, Survives Dismissal
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In Modny et al v. Foley Hoag LLP et al, 24-CV-5586 (JMF), 2025 WL 487308 (S.D.N.Y. Feb. 12, 2025), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s national origin discrimination claims. From the decision: [T]he Court rejects the Moving Defendants’ challenge to Modny’s national origin disparate treatment claim under Title VII, the NYCHRL,…

Read More National Origin, and Other, Discrimination Claims Survive Dismissal
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In Schoenadel v. YouGov America Inc., 22-cv-10236 (AS), 2025 WL 371089 (S.D.N.Y. Feb. 3, 2025), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s retaliation claims under Title VII of the Civil Rights Act of 1964, the New York State Human Rights Law, and the New York City Human Rights Law. Here held the…

Read More Retaliation Claims Survive Summary Judgment; Adverse Actions Included Exclusion From Meetings
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In Schoenadel v. YouGov America Inc., 22-cv-10236 (AS), 2025 WL 371089 (S.D.N.Y. Feb. 3, 2025), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s gender-based discrimination claims under Title VII of the Civil Rights Act of 1964, the New York State Human Rights Law, and the New York City Human Rights Law.…

Read More Citing “Mama Fratelli” Nickname, Court Denies Summary Judgment on Title VII Gender Discrimination/Constructive Discharge Claim
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In Pachura v. Lloyd J. Austin III, 6:21-cv-316 (AMN/MJK), 2025 WL 371786 (N.D.N.Y. Feb. 3, 2025), the court, inter alia, dismissed plaintiff’s hostile work environment sexual harassment claim. While the court found that plaintiff raised a triable issue of fact as to whether the work environment was objectively and subjectively “hostile,” the court found that…

Read More Hostile Work Environment Sexual Harassment Claim Dismissed; Conduct Not Imputable to Employer
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In Konate v. Actalent, Inc., Civil Action No. 23-4210 (ZNQ) (JBD), 2025 WL 289212 (D.N.J. Jan. 24, 2025), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s claims of pregnancy discrimination. As to plaintiff’s claim under Title VII of the Civil Rights Law of 1964 – after explaining the black-letter law applicable to this…

Read More Pregnancy-Based Discriminatory Termination Claims, Under Title VII and NJLAD, Survive Dismissal
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In Armstrong v. Aura Healthcare, LLC, No. 3:24-cv-723 (VAB), 2025 WL 357839 (D.Conn. Jan. 31, 2025), the court, inter alia, held that plaintiff did not sufficiently allege a hostile work environment. From the decision: Ms. Armstrong alleges that she was subjected to an objectively hostile or abusive work environment, as she was subjected to hostile…

Read More Hostile Work Environment Claims Dismissed; “Idiot” Comment Insufficient
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