In Gehlaut v. New York City Department of Education, No. 24-1741 (2d Cir. 2025), the U.S. Court of Appeals for the Second Circuit affirmed the dismissal of plaintiff’s retaliation claim asserted under Title VII of the Civil Rights Act of 1964. From the decision: To state a claim for retaliation under Title VII, “the plaintiff…
Read More Title VII Retaliation Claim Properly Dismissed; Temporal Proximity Not ShownIn Pagan v. Research Foundation of the City University of New York et al, No. 24-CV-6500 (RA), 2025 WL 2793685 (S.D.N.Y. Oct. 1, 2025), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s claim of religion-based discrimination asserted under Title VII of the Civil Rights Act of 1964. This decision is a good example…
Read More Title VII Religion-Based Termination Claim Sufficiently AllegedIn Carter-Marks v. Alstom Transport USA Inc., 2025 WL 2680998 (E.D.N.Y. Sept. 19, 2025), the court, inter alia, granted defendants’ motion for summary judgment on plaintiff’s claim of hostile work environment asserted under Title VII of the Civil Rights Act of 1964. This decision illustrates the principle, cited often by courts, that actions that might…
Read More Title VII Hostile Work Environment Claim Dismissed; Alleged “Intimidation” InsufficientIn Izuogu v. Credit Agricole Corporate and Investment Bank, New York, 24 Civ. 4329 (DEH), 2025 WL 2806683 (S.D.N.Y. Oct. 2, 2025), the court, inter alia, granted defendants’ motion to dismiss plaintiff’s hostile work environment claims under Title VII of the Civil Rights Act of 1964 and 42 U.S.C. 1981. From the decision: To establish…
Read More Hostile Work Environment Claims Dismissed; Remarks, Gossip, False Complaint Did Not Reference Race or National OriginIn Lindsey v. Citigroup Global Markets Inc., 1:23-cv-10166-ALC, 2025 WL 2781281 (S.D.N.Y. Sept. 30, 2025), the court discussed and applied the “continuing violation” doctrine under Title VII of the Civil Rights Act of 1964. In sum, plaintiff alleges that she was subjected to a hostile work environment, commencing in 2007 with an alleged sexual assault,…
Read More Title VII Hostile Work Environment Claim Survives Motion to Dismiss; Applicability of “Continuing Violation” Doctrine Must Await Further Factual DevelopmentIn Mehta, Anisha v. DLA Piper LLP, 23 Civ. 4757 (AT), 2025 WL 2771659 (S.D.N.Y. Sept. 29, 2025), the court denied defendant’s motion for summary judgment on plaintiff’s claims of pregnancy discrimination asserted under Title VII of the Civil Rights Act of 1964, the New York State Human Rights Law, and the New York City…
Read More Pregnancy Discrimination Claims Survive Summary Judgment Against DLA PiplerIn Carey v. NYS Department of Health, 2025 WL 2732918 (S.D.N.Y. Sept. 25, 2025), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s sex-based hostile work environment claims asserted under the New York State and City Human Rights Laws. This decision illustrates the difference between the relatively restrictive federal law, on the…
Read More Sex-Based Hostile Work Environment Claims Survive Under New York State and City Human Rights LawsIn Oji v. Douglas A. Collins, Secretary, Department of Veterans Affairs, 2025 WL 2624975 (E.D.N.Y. Sept. 11, 2025), the court, inter alia, granted defendant’s motion for summary judgment on plaintiff’s race-based hostile work environment. From the decision: Though it is undisputed that Plaintiff subjectively viewed his working environment as a hostile one, Plaintiff has cited…
Read More Race-Based Hostile Work Environment Claim Dismissed; Alleged Comments by Non-Supervisor Held InsufficientIn Varney v. Health Carousel, LLC, Case No. 1:24-cv-624, 2025 WL 2605783 (S.D.Ohio Sept. 9, 2025), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s pregnancy/lactation-related hostile work environment constructive discharge claim asserted under Title VII of the Civil Rights Act of 1964. This decision underscores that, when evaluating hostile work environment claims, it…
Read More Pregnancy/Lactation-Related Hostile Work Environment Claims Survive DismissalNew York is a city of ambition, hustle, and incredible opportunity. But for some, the daily grind is made unbearable by a different kind of challenge: workplace bullying. While it’s a pervasive issue across the country, New York’s unique legal landscape offers both hurdles and pathways for those who are targeted. So, what exactly is…
Read More Workplace Bullying in New York