Hostile Work Environment Claim Dismissed Against Center for Disability Services

In Raucci v. Center for Disability Services, Inc., 19-cv-1002, 2020 WL 777269 (N.D.N.Y. Feb. 18, 2020), the court, inter alia, dismissed plaintiff’s hostile work environment claim.

From the decision:

In the present matter, the Court finds that Plaintiff has failed to plead facts alleging that she suffered abuse rising to the level of a hostile work environment. In her response to Defendant’s motion, Plaintiff first argues that she pled a hostile work environment claim “when she told [Defendant] that she was pregnant, her supervisors took disciplinary action against her by informing her they were concerned about previous approved leaves of absence.” Dkt. No. 28 at 7 (citing Dkt. No. 15 at ¶ 18). Further, Plaintiff claims that her amended complaint details her request for a medical accommodation in the form of a limited workweek and Defendant’s denial of that request and subsequent order that she go on disability. See id. (citing Dkt. No. 15 at ¶¶ 21-23). Plaintiff argues that this demonstrates Defendant’s hostility towards her[] sex/pregnancy and that “[i]t is plausible (and common sense) that the defendant’s insistence that she go on disability, rather than work, was rooted in its illegal, discriminatory bias and hostility towards her sex/pregnancy.” Id. Finally, Plaintiff contends that Defendant’s hostility towards her sex/pregnancy is demonstrated by Defendant’s intention to demote her upon her return to work.

The court – after citing as examples a number of cases in which courts dismissed similar claims – agreed with defendant that “these allegations fall far short of demonstrating sufficiently severe or pervasive conditions that are necessary to support a Title VII hostile work environment claim.”