Title VII of the Civil Rights Act of 1964

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In Jordan v. United Health Group Inc., No. 18-2268, 2019 WL 4071943 (2d Cir. Aug. 29, 2019) (Summary Order), the Second Circuit, inter alia, affirmed the dismissal of plaintiff’s retaliation claim under Title VII of the Civil Rights Act of 1964. Here, plaintiff contends that she was terminated in retaliation for filing a charge with…

Read More 2d Circuit Affirms Dismissal of Title VII Retaliation Claim; More Than One-Year Gap Too Attenuated to Show Causation
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In Jordan v. United Health Group Inc., No. 18-2268, 2019 WL 4071943 (2d Cir. Aug. 29, 2019) (Summary Order), the Second Circuit, inter alia, affirmed the dismissal of plaintiff’s race-based hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. The court briefly summarized the law: “A hostile work environment…

Read More 2d Circuit Affirms Dismissal of Race-Based Hostile Work Environment Claim
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In Jordan v. United Health Group Inc., No. 18-2268, 2019 WL 4071943 (2d Cir. Aug. 29, 2019) (Summary Order), the Second Circuit, inter alia, affirmed the dismissal of plaintiff’s race discrimination claim asserted under Title VII of the Civil Rights Act of 1964. After briefly summarizing the law – namely, that “[t]o prevail on [a…

Read More 2d Circuit Affirms Dismissal of Title VII Race Discrimination Claim; Absent/Tardy Co-Worker Comparators Were Not “Similarly Situated”
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In Coku v. The New York Presbyterian Hospital et al, 17-cv-2488, 2019 WL 3779507 (S.D.N.Y. Aug. 12, 2019), the court, inter alia, dismissed plaintiff’s hostile work environment claim. After summarizing the relevant legal standards, and noting that “the standard for establishing a hostile work environment is high”, the court noted that plaintiff did not meet…

Read More Hostile Work Environment Claim Dismissed; Alleged Mistreatment Was Not Due to Protected Characteristic
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In Menaker v. Hofstra University, 18-3089-cv, 2019 WL 3819631 (2d Cir. Aug. 15, 2019), the Second Circuit vacated the dismissal of plaintiff’s sex discrimination claim asserted under Title VII of the Civil Rights Act of 1964. The court summarized its holding(s) as follows: (1) Where a university (a) takes an adverse employment action against an…

Read More Second Circuit Vacates Dismissal of Hofstra Tennis Coach’s Sex Discrimination Claim
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In MacAlister v. Millennium Hotels & Resorts et al, 2019 WL 3765825 (S.D.N.Y. August 9, 2019), the court held, inter alia, that plaintiff – a white American woman over the age of 40 – sufficiently alleged discrimination and a hostile work environment based on her age. gender and race. As to plaintiff’s discrimination claims, the…

Read More “Old White Bitch” Among Comments Held Sufficient to Allege Age/Race/Gender Discrimination & Hostile Work Environment Claims
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In Gayle v. Children’s Aid College Prep Charter School et al, 18-cv-9874, 2019 WL 3759097 (SDNY July 29, 2019), the court dismissed the sexual harassment claim of plaintiff – an employee of a federally-funded educational institution – brought under Title IX of the Education Amendments of 1972, finding that Title VII of the Civil Rights…

Read More Instructor at Federally-Funded School Had Exclusive Remedy for Sexual Harassment Under Title VII, Not Title IX, Court Rules
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In Young v. Town of Islip et al, 2019 WL 3412113 (E.D.N.Y. July 29, 2019) – in which plaintiff asserted, inter alia, claims of race discrimination and retaliation in violation of Title VII of the Civil Rights Act of 1964 – the court denied plaintiff’s motion for a new trial under Federal Rule of Civil…

Read More Verdict Sheet Did Not Confuse Jury in Race Discrimination/Hostile Work Environment Claim, Court Holds
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In Guity v. Uniondale Union Free School Dist., 2019 WL 3402280 (E.D.N.Y. July 26, 2019), the court, inter alia, dismissed plaintiff’s race/ethnicity-based hostile work environment claim under Title VII of the Civil Rights Act of 1964. Plaintiff – a high school Spanish teacher – alleged among other things that she was targeted because she was…

Read More Title VII Hostile Work Environment Claim Dismissed Against Uniondale Union Free School District;
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In Babbitt v. Koeppel Nissan, Inc., 2019 WL 3296984 (EDNY July 23, 2019) – an employment discrimination, sexual harassment, and retaliation case brought under Title VII of the Civil Rights Act of 1964 – the court ruled on the parties’ respective motions to compel discovery. One issue addressed by the court – which has become…

Read More Social Media Discovery Compelled (in Part) in Sexual Harassment Case
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