In Sedhom v Suny Downstate Medical Center, No. 155837/2017, 2020 WL 1514710, 2020 N.Y. Slip Op. 30881(U) (N.Y. Sup Ct, New York County Mar. 27, 2020), the court, inter alia, dismissed plaintiff’s claim for hostile work environment under the New York State and City Human Rights Laws. As to the state law, the court held:…
Read More Hostile Work Environment Claim Dismissed Against SUNY Downstate Medical CenterIn Anderson v. New York City Health and Hospitals Corporation et al, 16-cv-1051, 2020 WL 1528101 (S.D.N.Y. March 31, 2020), the court, inter alia, upheld the dismissal on summary judgment of plaintiff’s hostile work environment claims under Title VII of the Civil Rights Act of 1964 and the New York City Human Rights Law. The…
Read More Hostile Work Environment Claim Dismissed Against NYC Health & Hospitals CorporationIn Yarrington v. Candor Central School District et al, 18-cv-1250, 2020 WL 1493920 (N.D.N.Y. March 27, 2020), the court (inter alia) granted defendants’ motion for summary judgment on plaintiff’s hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. The court summarized the law as follows: In order to state…
Read More Hostile Work Environment Claim Dismissed; Conduct Evidenced “Personality Conflicts”In a recent case, Martin v. New York State Department of Corrections and Community Supervision, 2020 WL 1514747 (2d Cir. March 30, 2020) (Summary Order), the court affirmed the dismissal of plaintiff’s hostile work environment claim asserted under Title VII of Civil Rights Act of 1964. This decision is instructive as to the standard applied…
Read More Hostile Work Environment Dismissal Affirmed; 2d Circuit Discusses & Applies Negligence Standard Under Title VIIIn Williams v. Anne Geiger and Department of Education, 2020 WL 1304397 (S.D.N.Y. March 19, 2020), the court, inter alia, dismissed plaintiff’s hostile work environment claim asserted under the Americans with Disabilities Act. In order to establish a hostile work environment claim, plaintiff was required to show two elements: (1) the workplace was permeated with…
Read More Disability-Based Hostile Work Environment Claim DismissedIn Kiraka v. M&T Bank, 2020 WL 1285632 (N.D.N.Y. March 18, 2020), the court, inter alia, dismissed plaintiff’s hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964. After summarizing the black-letter law regarding such claims, the court explained: [Plaintiff] fails to state a plausible claim under Title VII. ……
Read More Hostile Work Environment Claim Dismissed; Allegations, Including Mocking of Accent, Held InsufficientIn Morales v. City of New York, New York Presbyterian Hospital, Columbia University Medical Center et al, 2020 WL 1150136 (S.D.N.Y. March 10, 2020), the court, inter alia, adopted a Magistrate Judge’s Report and Recommendation that defendants’ motions to dismiss plaintiff’s aiding and abetting discrimination and hostile work environment sexual harassment and retaliation. This case…
Read More Hostile Work Environment Sexual Harassment and Retaliation Claims Survive DismissalIn Pignone v. United Parcel Service, Inc., 2020 WL 1140509 (N.D.N.Y. March 9, 2020), the court dismissed plaintiff’s hostile work environment claim, finding that there was no act committed by defendant within the relevant statute of limitations (here, three years under the New York State Human Rights Law). (while the court denied defendant’s motion to…
Read More Court Dismisses Hostile Work Environment Claim Against UPS on Statute of Limitations GroundsIn EEOC v. United Health Programs of America, Inc. and Cost Containment Group, Inc., 14-CV-3673, 2020 WL 1083771 (EDNY March 6, 2020), the court, inter alia, upheld a jury verdict in favor of plaintiffs, who alleged that they were subjected to a religious discrimination and a religion-based hostile work environment in violation of Title VII…
Read More Religion-Based Discrimination and Hostile Work Environment Jury Verdict for Plaintiff UpheldIn Triana v. NYC Health & Hospitals, No. 152276/2019, 2020 NY Slip Op 30605(U), 2020 WL 1031379 (N.Y. Sup Ct, New York County Feb. 20, 2020), the court, inter alia, dismissed plaintiff’s race-based hostile work environment claims asserted under 42 USC §§ 1981 and 1983 and the New York City Human Rights Law. The court…
Read More Hostile Work Environment Claim Dismissed; Accent Comments Held Insufficient