Title VII of the Civil Rights Act of 1964

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In Smith v. St. Joseph’s Medical Center et al, 2024 WL 2058619 (S.D.N.Y. May 7, 2024), the court, inter alia, granted defendants’ motion for summary judgment on plaintiff’s “pattern or practice” discrimination claim. The court explained the “black letter law” applicable to this theory as follows: A pattern or practice theory of discrimination requires a…

Read More Court Grants Summary Judgment Dismissing “Pattern or Practice” Religious Discrimination Claim
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In Qin v. Vertex, Inc., 2024 WL 1920379 (3d Cir. May 2, 2024), the court affirmed the lower court’s grant of summary judgment dismissing plaintiff’s hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: Qin alleged that he suffered a hostile work environment. He points to…

Read More Hostile Work Environment Claim Properly Dismissed; Three Comments Over Nearly Two Decades Insufficient
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In Painadath v. Melissa Lattanzio, et al, No. 22-3604, 2024 WL 1836500 (E.D.Pa. April 26, 2024), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s hostile work environment sexual harassment claim. From the decision: Construed liberally, Painadath pleads a hostile work environment sexual harassment claim. Painadath alleges that Mrs. Susan made a sexual advance…

Read More Hostile Work Environment Sexual Harassment Claim Sufficiently Alleged; Question of Severity or Pervasiveness Best Evaluated at Summary Judgment
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In Johnson v. School District of Philadelphia, 2024 WL 1773358 (E.D.Pa. April 24, 2024), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s race-based hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964 and 42 U.S.C. § 1981. From the decision: For racist comments, slurs, and jokes to…

Read More Hostile Work Environment Claims Dismissed; Comments Invoking “Racial Stereotypes” Did Not Amount to a “Steady Barrage”
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In Reed v. Fortive Corporation et al, 2024 WL 1756110 (2d Cir. April 24, 2024), the U.S. Court of Appeals for the Second Circuit, inter alia, affirmed the dismissal of plaintiff’s claim of quid pro quo sexual harassment asserted under Title VII of the Civil Rights Act of 1964. From the decision: To state a quid pro…

Read More Quid Pro Quo Sexual Harassment Claim Properly Dismissed; Alleged Invitation Did Not Constitute a “Sexual Advance”
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In Maryam v. LSG Sky Chefs, No. 1:23-cv-914-SDG, 2024 WL 1195535 (N.D.Ga. March 20, 2024), the court held that plaintiff pled sufficient facts to support a sex discrimination claim, based on a tangible employment action harassment theory, in violation of Title VII of the Civil Rights Act of 1964. From the decision: Sexual harassment in…

Read More Title VII Tangible Action Sexual Harassment Claim Sufficiently Alleged, Court Holds
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In Howard v. State of Arizona et al, 2024 WL 1619400 (D.Ariz. April 15, 2024), the court granted defendant’s motion to dismiss plaintiff’s hostile work environment asserted under Title VII of the Civil Rights Act of 1964. From the decision: Title VII is not meant as “a general civility code” and “sporadic use of abusive…

Read More Title VII Race/Sex-Based Hostile Work Environment Claims Dismissed; Single Incident Held Insufficient
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In Muldrow v. City of St. Louis, Missouri, 2024 WL 1642826 (U.S. April 17, 2024), the U.S. Supreme Court (in an opinion authored by Justice Kagan) held that, in the context of a claim of discrimination in a form of a transfer (here, because of the plaintiff’s sex) in violation of Title VII of the…

Read More U.S. Supreme Court Clarifies Standard For Title VII Discriminatory Transfer Claims
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In Mayorga v. Diet Center LLC d/b/a Heart Attack Grill, 2024 WL 1574362 (9th Cir. April 11, 2024), the court affirmed the lower court’s award of summary judgment on plaintiff’s employment discrimination claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: Even though the First Amended Complaint (“FAC”) alleges…

Read More Title VII Hostile Work Environment and Constructive Discharge Claims Properly Dismissed, Ninth Circuit Holds
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