Title VII of the Civil Rights Act of 1964

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In U.S. Equal Employment Opportunity Commission v. Green JobWorks, LLC, Civil Action No. RDB-21-1743, 2022 WL 1213478 (D.Md. April 25, 2022), the court held that plaintiff sufficiently alleged claims of sex discrimination in violation of Title VII of the Civil Rights Act of 1964. After summarizing the “black letter” law, the court applied it to…

Read More EEOC Sufficiently Alleges Sex Discrimination on a “Pattern or Practice” Theory, Court Holds
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In Robinson v. Department of Vocational Rehabilitation, No. 22-cv-5098 RJB-JRC, 2022 WL 1237671 (W.D. Wash. April 27, 2022), the court adopted a Report & Recommendation to dismiss plaintiff’s race discrimination and sexual harassment claims, asserted under Title VII of the Civil Rights Act of 1964. This decision relates to a crucial procedural element of Title…

Read More Title VII Race Discrimination, Sexual Harassment Claims Dismissed Due to Failure to Exhaust Administrative Remedies
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In Dunham v. Hartford Board of Education, No. HHD-CV-206129681-S, 2022 WL 1223917 (Conn. Super. April 26, 2022), the court, inter alia denied defendant’s motion for summary judgment on plaintiff’s hostile work environment sexual harassment claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: A hostile work environment claim requires…

Read More Sexual Harassment (Hostile Work Environment) Claim Survives Summary Judgment Against Hartford Board of Education
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In Saketkoo v. Administrators of Tulane Educational Fund, 2022 WL 1183824 (C.A.5 (La.), 2022), the U.S. Court of Appeals for the Fifth Circuit, inter alia, affirmed the lower court’s grant of summary judgment in favor of defendant on plaintiff’s gender-based hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964.…

Read More Gender-Based Title VII Hostile Work Environment Claim Properly Dismissed: Fifth Circuit
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In Miller v. New York State Police et al, 2022 WL 1133010 (2d Cir. April 18, 2022), the U.S. Court of Appeals for the Second Circuit, inter alia, affirmed the lower court’s dismissal (on summary judgment) of plaintiff’s race-based hostile work environment claim. After summarizing the well-established black-letter law of hostile work environment claims, the…

Read More Race-Based Hostile Work Environment Claim Properly Dismissed; Alleged 12 Incidents Over 3 Years Insufficient
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In Davis v. Elwyn, Inc., 20-cv-05798, 2022 WL 970842 (E.D.Pa. March 31, 2022), the court, inter alia, dismissed plaintiff’s hostile work environment claims asserted under Title VII of the Civil Rights Act of 1964. Plaintiff, who worked as a Mental Health Program Specialist for defendant, alleged that defendant subjected her to a hostile work environment…

Read More Sex/Race-Based Hostile Work Environment Claims Dismissed; Mental Health Specialist Did Not Suffer “Objectively” Hostile Environment Resulting From Patient’s Alleged Harassment
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In Taylor v. Haaland, 2022 WL 990682 (D.D.C. March 31, 2022), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s hostile work environment claim. After summarizing the “black letter” law governing such a claim, the court applied it to the facts: Here, Taylor argues that the Department created a hostile work environment by: (1)…

Read More Hostile Work Environment Claim Dismissed; “Unpleasant” and “Offensive” Conduct Insufficient
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In Sherman v. Kendall, CIV-21-484-F, 2022 WL 1094617 (W.D.Okla. April 12, 2022), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s race-based hostile work environment and constructive discharge claims asserted under Title VII of the Civil Rights Act of 1964. From the decision: Upon review, the court again concludes that Sherman has failed to…

Read More Lack of Racial Motivation Dooms Hostile Work Environment, Constructive Discharge Claims
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In Byars v. Asbury Management Services, LLC, 2022 WL 468598 (S.D.Miss. Feb. 15, 2022), the court denied defendant’s motion for summary judgment on plaintiff’s hostile work environment sexual harassment claim asserted under Title VII of the Civil Rights Act of 1964. In sum, plaintiff alleged, among other things, that her coworker (Massey) sexually harassed her…

Read More Title VII Sexual Harassment Hostile Work Environment Claim Survives Summary Judgment; Text Messages Did Not Establish That Sexual Harassment Was “Welcomed”
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In Franks v. Edison Electric Institute, 20-cv-3393, 2022 WL 971157 (D.D.C. March 31, 2022), the court, inter alia, dismissed plaintiff’s hostile work environment claim. It explained: Plaintiff’s hostile work environment claims are all rooted in Plaintiff’s relationship with her supervisor, Kathy Steckelberg, and the actions Steckelberg took against her. Franks points to, for example, Steckelberg’s…

Read More “Silent Treatment” Etc. Did Not Amount to Hostile Work Environment, Court Holds
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