Title VII of the Civil Rights Act of 1964

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In Syeed et al v. Bloomberg L.P., 1:20-cv-7464-GHW, 2022 WL 3447987 (S.D.N.Y. Aug. 17, 2022), the court, inter alia, denied (in part) defendant’s motion to dismiss plaintiff’s claims of retaliation asserted under the New York State and City Human Rights Laws.[1]The court dismissed plaintiff’s claims asserted under Title VII of the Civil Rights Act of…

Read More Retaliation Claims Sufficiently Alleged, in Part, Against Bloomberg L.P.
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A recent decision, Carroll v. Amazon Data Services, Inc., No. 1:21-cv-01177 (RDA/TCB), 2022 WL 3161895 (E.D. Va. Aug. 8, 2022), illustrates that even workplace conduct that is, by most measures, unpleasant does not necessarily give rise to an actionable “hostile work environment” claim that violates Title VII of the Civil Rights Act of 1964. From…

Read More Hostile Work Environment Claim Dismissed; Hair Comments and Touching (While Troubling) Was Not Actionable Under Title VII
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In Gray v. Koch Foods, Inc. et al, 2022 WL 141533 (M.D.Ala. Jan. 14, 2022), the court, inter alia, denied defendants’ motion for summary judgment on plaintiff’s claim of hostile work environment sexual harassment asserted under Title VII of the Civil Rights Act of 1964. From the decision: The facts at issue here do not…

Read More Sexual Harassment Claim Survives Summary Judgment; Conduct Was Sufficiently “Severe” Even if Not “Pervasive”
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In Delagrange v. Weaver Popcorn Manufacturing, Inc., 1:20-CV-451-HAB, 2022 WL 3081978 (N.D.Ind. Aug. 3, 2022), the court, inter alia, dismissed plaintiff’s same-sex sexual harassment claim asserted under Title VII of the Civil Rights Act of 1964. The court summarized the black-letter law on this issue, arising from U.S. Supreme Court precedent, as follows: Same-sex harassment…

Read More Same-Sex Sexual Harassment Claim Dismissed
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In Felder v. MGM National Harbor, LLC, No. 20-2373, 2022 WL 2871905 (4th Cir. July 21, 2022), the court, inter alia, vacated the lower court’s order dismissing, for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6), plaintiff’s claim of color-based discrimination asserted under Title VII of the Civil Rights Act of…

Read More Fourth Circuit Vacates Dismissal of Title VII Color-Based Discrimination Claim
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In McKenna v. Santander Investment Securities, Inc. et al, 21cv941 (DLC), 2022 WL 2986588 (S.D.N.Y. July 28, 2022), the court, inter alia, held that plaintiff’s pregnancy discrimination claim (in part) survived summary judgment. Here, plaintiff alleged pregnancy discrimination based on two pregnancies, one in 2019, and one in 2020.  The court reached different decisions regarding…

Read More Pregnancy Discrimination Claim Survives Summary Judgment (In Part) Against Santander Investment Securities
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In Webb v. City of Venice, No. 8:19-cv-3045-TPB-TGW 2022 WL 2967291 (M.D.Fla. July 27, 2022), the court, inter alia, denied defendant’s motion for judgment as a matter of law on plaintiff’s claim of race-based hostile work environment claim. As to the issue of the existence of a hostile work environment, the court explained: This is…

Read More Race-Based Hostile Work Environment Jury Verdict Upheld; Evidence Included Use of “N-Word”
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In Robinson v. Attractions Lodging, Inc., 6:20-cv-32-EJK, 2022 WL 2904869 (M.D.Fla. July 22, 2022), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s race and national origin based hostile work environment claims asserted under Title VII of the Civil Rights Act of 1964. From the decision: As to Plaintiff’s claim that the…

Read More Race/National Origin-Based Hostile Work Environment Claims Survive Summary Judgment
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In Mellett v. City of Philadelphia, No. 20-cv-1629-JMY, 2022 WL 2391141 (E.D.Pa. July 1, 2022), the court, inter alia, denied defendant’s motion for summary judgment as to plaintiff’s retaliation claim. From the decision: Plaintiff has brought forth evidence that Defendant’s alleged retaliatory conduct occurred within days of her complaining about Lieutenant Frank’s conduct and that…

Read More Retaliation Claim, Arising From “Antagonism” Following Complaints of Sexual Harassment, Survives Summary Judgment
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In Sarraj v. Northern Virginia Electric, 2022 WL 2820553 (E.D.Va. July 18, 2022), the court, inter alia, dismissed plaintiff’s hostile work environment claims based on race, age, and sex. Initially, the court held that plaintiff – who is over 40 and Iraqi-Kurish – did not sufficiently allege an race and age-based hostile work environment claim,…

Read More Sex-Based Hostile Work Environment Claim Dismissed; Single Comment Insufficient
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