Title VII of the Civil Rights Act of 1964

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In Clarke v. New York City Department of Education et al, 2020 WL 6047426 (E.D.N.Y. Oct. 13, 2020), the court, inter alia, denied defendants’ motion for summary judgment on plaintiff’s pregnancy discrimination claims asserted under Title VII of the Civil Rights Act of 1964, the New York State Human Rights Law, and the New York…

Read More Pregnancy Discrimination Claims Survive Summary Judgment Against the NYC Dept. of Education
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Ordinarily I write about decisions issued by New York state courts, federal district courts located in New York, the U.S. Court of Appeals for the 2nd Circuit, and, of course, the U.S. Supreme Court. Here, however, I’ll make an exception and stray from these jurisdictional/geographic limits, in order to discuss a decision issued by the…

Read More “N-Word” Did Not Give Rise to Hostile Work Environment: SCOTUS-Nominee Amy Coney Barrett
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In Hodge v. ABACO, LLC, 20-1186-cv (2d Cir. Oct. 9, 2020) (Summary Order), the U.S. Court of Appeals for the Second Circuit, inter alia, affirmed the dismissal of plaintiff’s retaliation claim asserted under Title VII of the Civil Rights Act of 1964. Here, the bad things that plaintiff alleged happened to her did not amount…

Read More Retaliation Claim Dismissal Affirmed; Exclusion From Meetings and Other Vaguely-Alleged Conduct Did Not Qualify as “Adverse Employment Actions”
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In Rodriguez v. County of Nassau, Nassau County Commission on Human Rights, 2020 WL 5948904 (2d Cir. Oct. 8, 2020) (Summary Order), the court, inter alia, affirmed the dismissal of plaintiff’s “failure to promote” gender discrimination claim. Plaintiff argued that (1) the Commission Chair harbored discriminatory views, telling plaintiff during her interview for the position that,…

Read More Gender Discrimination Claim Fails in Light of Prior Denial of Discriminatory Comment
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In Antoine v. Brooklyn Maids 26, Inc. et al, 19-cv-5676, 2020 WL 5752186 (E.D.N.Y. Sept. 26, 2020), the court, inter alia, held that plaintiff sufficiently alleged hostile work environment sexual harassment against defendants, and therefore granted plaintiff’s motion for a default judgment. From the decision: Plaintiff’s hostile work environment claim hinges primarily on two incidents.…

Read More Sexual Harassment/Hostile Work Environment Claim Sufficiently Alleged Against Brooklyn Maids 26, Inc. and Individual Defendant
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In Toombs v. New York City Housing Authority, 2020 WL 5650423 (2d Cir. Sept. 23, 2020) (Summary Order), the court, inter alia, affirmed the dismissal of plaintiff’s race discrimination claim asserted under Title VII of the Civil Rights Act of 1964. After summarizing the law, the court issued the following explanation as to plaintiff’s prima…

Read More Race Discrimination Case Dismissal Affirmed; Vague, Secondhand Comments Insufficient
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In Milord-Francois v. The New York State Office of the Medicaid Inspector General et al, 2020 WL 5659438 (SDNY Sept. 23, 2020), the court, inter alia, granted defendants’ motion for summary judgment on plaintiff’s hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. The Court explained that plaintiff’s hostile…

Read More Hostile Work Environment Claim Dismissed; Conduct by Subordinate Employee Held Insufficient
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In Green v. New York City Transit Authority et al, 15-cv-8204, 2020 WL 5632743 (S.D.N.Y. Sept. 21, 2020), the court, inter alia, denied defendants’ motion for summary judgment on plaintiff’s sexual harassment/hostile work environment claim. Federal & State Law As to plaintiff’s claims under Title VII of the Civil Rights Act of 1964 and the…

Read More Sexual Harassment/Hostile Work Environment Claim Survives Summary Judgment; Evidence Included Name-Calling, Pornography
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In Zheng-Smith v. Nassau Health Care Corporation, 18-cv-2585, 2020 WL 55117486 (EDNY Sept. 14, 2020), the court, inter alia, dismissed plaintiff’s hostile work environment claims alleged under Title VII of the Civil Rights Act of 1964 and the New York State Human Rights Law. The court explained the black-letter law as follows: Although courts are…

Read More Hostile Work Environment Claim, Based on Mocking of Accent, Dismissed
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