Hostile Work Environment Claim Dismissed; Alleged Mistreatment Was Not Due to Protected Characteristic

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 that standard here.

From the decision:

Dr. Coku has not presented sufficient evidence upon which a jury could conclude that she suffered a hostile work environment. Even if Dr. Coku suffered mistreatment at the hand of Dr. Stiles, for the same reasons discussed above, no reasonable jury could conclude that she suffered mistreatment “because of … [a] protected characteristic,” rather than her poor performance or Dr. Stiles’s “[p]ersonal animosity” towards her. Rivera, 743 F.3d at 20; Pesok, 235 F. Supp. 2d at 288. Because Dr. Coku has failed to present sufficient evidence from which a jury could conclude that her alleged mistreatment was motivated by discrimination, the Court grants summary judgment on her hostile work environment claim.

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