Title VII of the Civil Rights Act of 1964

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In Akhtar v. Saudia d/b/a Saudi Arabian Airlines Corp., 2021 WL 1758807 (S.D.N.Y. May 4, 2021), the court held, inter alia, that plaintiff sufficiently alleged national origin and gender-based hostile work environment claims under Title VII of the Civil Rights Act of 1964 and the New York State and City Human Rights Laws. As to…

Read More Gender and National Origin-Based Hostile Work Environment Claims Continue Against Saudi Arabian Airlines
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In Taylor v. The Children’s Village et al, 2021 WL 1581568 (SDNY April 21, 2021), the court, inter alia, dismissed plaintiff’s discrimination claim, asserted under Title VII of the Civil Rights Act of 1964, based on her status as a crime victim. This decision illustrates Title VII’s relatively narrow scope: Plaintiff suggests throughout the amended…

Read More Title VII Discrimination Claim, Based on Status as Crime Victim, Dismissed
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In Henry v. McDonald, 2021 WL 1309729 (E.D.N.Y. March 31 2021), the court, inter alia, dismissed plaintiff’s hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: Plaintiff has failed to present evidence that Defendant discriminated against him based on any protected characteristic to support his hostile…

Read More Hostile Work Environment Claim Dismissed; Discrimination Based on “Educational Background” Not Actionable Under Title VII
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In Grimes-Jenkins v. Consolidated Edison Company of New York, Inc., 2021 WL 1226658 (S.D.N.Y. March 31, 2021), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s race-based hostile work environment claims under Title VII of the Civil Rights Act of 1964, the New York State Human Rights Law, and the New York…

Read More Race-Based Hostile Work Environment Claims Survive Summary Judgment Against Con Edison; Slavery Comment Cited
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In Espinosa v. Weill Cornell Medical College, 18 Civ. 11665, 2021 WL 1062592 (S.D.N.Y. March 19, 2021), the court, inter alia, denied defendants’ motion for summary judgment on plaintiff’s gender-based hostile work environment claim under Title VII of the Civil Rights Act of 1964, the New York State Human Rights Law, and the New York City Human…

Read More Gender-Based Hostile Work Environment Claim Against Weill Cornell Medical College Survives Summary Judgment
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In Espinosa v. Weill Cornell Medical College, 18 Civ. 11665, 2021 WL 1062592 (S.D.N.Y. March 19, 2021), the court, inter alia, denied defendants’ motion for summary judgment on plaintiff’s gender discrimination claim. From the decision: Espinosa adduces sufficient facts upon which the trier of fact may reasonably base an inference of gender discrimination. Direct evidence…

Read More Gender Discrimination Claim Against Weill Cornell Medical College Survives Summary Judgment
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In Felton v. Monroe Community College et al, 6:20-CV-06156, 2021 WL 1132411 (W.D.N.Y. March 24, 2021), the court held, inter alia, that plaintiff sufficiently alleged race discrimination, and denied defendant’s motion to dismiss under Federal Rule of Civil Procedure 12(b)(6). From the decision: Plaintiff’s allegations as to discriminatory motive are admittedly thin. However, construing Plaintiff’s…

Read More Race Discrimination Claim Sufficiently Alleged Against Monroe Community College
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A recent case, Ellis v. Bank of New York Mellon Corp., 2021 WL 829620 (3d Cir. March 4, 2021), involves an increasingly-common scenario: an employee of a (non-public) employer suffers a negative job action due to their outside-work social-media posting(s). In this case, the plaintiff (who is white) was terminated following her alleged Facebook post…

Read More Title VII Race Discrimination Dismissal Affirmed; Termination For Controversial Social Media Posts Was Not Unlawful Discrimination
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In Ali v. Westchester Medical Center et al, 2021 WL 1022615 (S.D.N.Y. March 17, 2021), the court, inter alia, granted defendants’ motion for summary judgment and dismissed plaintiff’s national origin discrimination claim. From the decision: Summary judgment is granted as to Ali’s claim of discrimination based on national origin. Ali has not established a prima…

Read More Medical Residency National Origin (Egyptian) Discrimination Claim Dismissed
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In Tromblee v. The State of New York et al, 19-cv-0638, 2021 WL 981847 (N.D.N.Y. March 16, 2021), the court, inter alia, held that plaintiff’s hostile work environment sexual harassment claim “far exceed[ed] legal sufficiency.” While defendants did not move to dismiss this claim, the court’s discussion is nevertheless instructive. The court summarized the “black…

Read More Sexual Harassment / Hostile Work Environment Claim Held Legally Sufficient; Allegations Include Sexually Demeaning Language & Touching
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