Hostile Work Environment

In Nofal v. IMCMV Times Square LLC et al, 22 Civ. 3104 (DEH), 2024 WL 1138928 (S.D.N.Y. March 15, 2024), the court, inter alia, granted defendant’s motion for summary judgment on plaintiff’s religion-based hostile work environment claim. Plaintiff, who is Muslim, predicated his religious-discrimination claim on a single comment, namely, telling plaintiff that if he…

Read More Religion-Based Hostile Work Environment Claim Dismissed; Single Comment Insufficient
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In Shkoza v. NYC Health & Hospitals Corporation, No. 20-CV-3646 (RA), 2024 WL 1116145 (S.D.N.Y. March 13, 2024), the court, inter alia, granted defendant’s motion for summary judgment on plaintiff’s hostile work environment sexual harassment claim asserted under the New York City Human Rights Law. From the decision: [Plaintiff] Shkoza also brings an underlying claim…

Read More Sexual Harassment Claim Dismissed; Shoulder Touching Insufficient, Court Holds
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In Floyd v. Jewish Bd. of Family and Children’s Services, No. 155925/2019, 2024 WL 1096320 (N.Y. Sup Ct, New York County Mar. 13, 2024), the court, inter alia, granted defendant’s motion for summary judgment dismissing plaintiff’s claim of hostile work environment based on plaintiff’s sexual orientation, in violation of the New York City Human Rights…

Read More Sexual Orientation-Based Hostile Work Environment Claim Dismissed
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In Kagel-Betts v Warren, No. 601810/2023, 81 Misc. 3d 1233(A), 202 N.Y.S.3d 723, 2024 N.Y. Slip Op. 50055(U), 2024 WL 237743 (N.Y. Sup. Ct. Suffolk Cty. Jan. 12, 2024), the court, inter alia, dismissed plaintiff’s hostile work environment claim asserted under the New York State Human Rights Law. As to that claim, the court explained:…

Read More Court Dismisses Hostile Work Environment Claim, Citing Lack of Examples of Alleged Conduct
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In Phillips v. Fashion Institute of Technology et al, No. 23-375-cv, 2024 WL 1005500 (2d Cir. March 8, 2024), the U.S. Court of Appeals for the Second Circuit, inter alia, vacated a lower court’s summary judgment on her retaliatory hostile work environment claims against an individual defendant who, according to plaintiff, threatened to “kill” her.…

Read More 2nd Circuit Vacates Dismissal of Black FIT Employee’s Retaliatory Hostile Work Environment Claims
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In Moore, Kim v. Hadestown Broadway Limited Liability Company, No. 23-CV-4837 (LAP), 2024 WL 989843 (S.D.N.Y. March 7, 2024), the U.S. District Court for the Southern District of New York (in an opinion authored by Judge Preska), inter alia, denied defendant’s motion to dismiss plaintiff’s race-based hostile work environment claims. (I wrote about the court’s…

Read More Actress Plausibly Alleges Race-Based Hostile Work Environment Claims Under NYS and NYC Human Rights Laws (But Not Title VII)
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In Moore, Kim v. Hadestown Broadway Limited Liability Company, No. 23-CV-4837 (LAP), 2024 WL 989843 (S.D.N.Y. March 7, 2024), the U.S. District Court for the Southern District of New York (in an opinion authored by Judge Preska), inter alia, denied defendant’s motion to dismiss plaintiff’s race-based discriminatory termination claims. The court discussed, and applied, the…

Read More Actress Plausibly Alleges Race-Based Discriminatory Termination, Court Holds
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In  Sawyers v. Christine McMahon, 1:23-cv-05494 (PAE) (SDA), 2024 WL 665681 (S.D.N.Y. Jan. 29, 2024), the court, inter alia, dismissed plaintiff’s hostile work environment claims. This decision, like many, illustrates that in order to be actionable, the alleged hostility must be connected to the plaintiff’s membership in a protected class (such as sex, race, etc.).…

Read More Lacking Link to Protected Class, Alleged Hostile Work Environment Claims Dismissed
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In Moll v. Telesector Resources Group, Inc., No. 20-3599, 2024 WL 820179 (2d Cir. Feb. 28, 2024), the U.S. Court of Appeals for the Second Circuit vacated the lower court’s order dismissing plaintiff’s claim of hostile work environment sexual harassment asserted under Title VII of the Civil Rights Act of 1964. From the decision: In…

Read More 2d Circuit Vacates Summary Judgment Dismissal of Title VII Hostile Work Environment Claim
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