“Reprehensible” Conduct (Including “Butt Swats” and “Spanking” Comments) Held Insufficient to Establish Sexual Harassment Hostile Work Environment Under NYS Human Rights Law
In Pawson v. Ross, 2016 NY Slip Op 02502 (App. Div. 3d Dept. March 31, 2016), an upstate appellate court held that defendants should have been granted summary judgment dismissing plaintiff’s complaint alleging hostile work environment sexual harassment under the New York State Human Rights Law. After stating the relevant law, the court proceeded to apply…
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