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Hostile Work Environment

In Collymore v. City of New York et al, 16-cv-8270, 2018 WL 3014093 (S.D.N.Y. June 14, 2018), the court, inter alia, dismissed plaintiff’s sexual harassment claim. “Title VII recognizes two forms of sexual harassment: direct discrimination (or ‘quid pro quo’) and ‘hostile workplace environment.’ … In addition to pleading abusive or offensive conduct, it is […]

From Matter of Stellar Dental Mgt. LLC v. New York State Div. of Human Rights, 2018 NY Slip Op 04483 (App. Div. 4th Dept. June 15, 2018): We conclude that there is substantial evidence to support the determination that petitioner discriminated against each complainant by subjecting her to a sexually hostile work environment (see Matter of Father […]

In Kimball v. Village of Painted Post, 2018 WL 2944337 (2d Cir. June 11, 2018) (Summary Order), the court, inter alia, affirmed the dismissal of plaintiff’s hostile work environment claim. In discussing plaintiff’s allegation of a hostile work environment based on pornography in the office, the court explained: [Plaintiff] has failed to establish that any […]

In Kobos v. Target Corporation et al, 15–cv-5573, 2018 WL 2943575 (E.D.N.Y. June 12, 2018), the court, inter alia, dismissed plaintiff’s hostile work environment claim. The court explained the legal standard: To establish a claim for a hostile work environment, a plaintiff must show “that the complained of conduct: (1) is objectively severe or pervasive—that […]

In Mondesir v. North Shore-Lij Health System, 2018 WL 2722866 (N.Y. Sup. Ct. No. 150572/2017 June 6, 2018), the court dismissed plaintiff’s race-based hostile work environment employment discrimination claim.[1]Plaintiff filed a Notice of Appeal on June 8, 2018. Specifically, the court rejected plaintiff’s contention that a racially hostile work environment was created by her supervisor’s reference […]

In Mayo-Coleman v. American Sugar Holdings, Inc., 14-cv-79, 2018 WL 2684100 (S.D.N.Y. June 5, 2018), the court, inter alia, held that a $1.7 million jury verdict in plaintiff’s favor on her sexual harassment/hostile work environment claims under Title VII of the Civil Rights Act of 1964 and the New York State Human Rights Law should […]

In Watkins v. New York City Health and Hospitals Corp., 2018 NY Slip Op 31054, 2018 WL 2445548 (N.Y. Sup. Ct. Index No. 152836/2013, May 11, 2018), the court, inter alia, dismissed plaintiff’s hostile work environment claims under the New York State and City Human Rights Laws. Here I will focus on the court’s assessment of […]

In Krause v. Kelehan, 17-CV-1045, 2018 WL 2021484 (N.D.N.Y. April 26, 2018), the court – applying the “continuing violation doctrine” – held that plaintiff sufficiently alleged a timely hostile work environment claim against the defendants.[1]The court also held, inter alia, that plaintiff’s discrimination claims survive dismissal. From the decision: Like Plaintiff’s discrimination claim, her hostile […]

In Campbell v. national Fuel Gas Distribution Corporation (2d Cir. 17-1820 May 25, 2018) (Summary Order), the court affirmed the dismissal of plaintiff’s Title VII gender discrimination claim. Initially, the court rejected plaintiff’s attempt to establish discrimination by comparing herself to male co-workers: We affirm for substantially the same reasons given by the district court […]

In Boliak v. Reilly, 2018 NY Slip Op 03745 (App. Div. 1st Dept. May 24, 2018), the court overturned the dismissal[1]Boliak v. Reilly, 2017 NY Slip Op 32010, Index No. 153941/2016, Judge Erika Edwards, Sept. 22, 2017. of plaintiff’s employment discrimination claims under the NYC Human Rights Law against Father Michael P. Reilly and others. From […]