Sexual Harassment

In Louis v. Window Rock Unified School District, No. CV-20-08193-PCT-DJH, 2022 WL 2132239 (D.Ariz. June 14, 2022), the court, inter alia, dismissed plaintiff’s claim of hostile work environment sexual harassment asserted under Title VII of the Civil Rights Act of 1964. Plaintiff’s claims arose from text messages exchanged between her and a non-party (the School…

Read More Text Message-Based Hostile Work Environment Sexual Harassment Claim Dismissed
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In Henry v. Ground, No. 153458/2021, 2022 WL 2158368 (N.Y. Sup Ct, New York County June 10, 2022), the court, inter alia, dismissed plaintiff’s hostile work environment sexual harassment claim asserted under the New York State and City Human Rights Laws. Plaintiff bases her claim on two incidents (one in July 2018, the other in…

Read More Hostile Work Environment Sexual Harassment Claim, Based on Off-Premises Conduct by Co-Workers, Dismissed
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In Kirstyn Crawford v. American Broadcasting Co., Inc., No. 157874/2021, 2022 WL 2066925 (N.Y. Sup Ct, New York County June 08, 2022), the court granted individual defendant Michael Corn’s motion to dismiss plaintiff’s hostile work environment sexual harassment claims, asserted under the New York State and City Human Rights Laws, as time-barred. Plaintiff (an ABC…

Read More Hostile Work Environment Sexual Harassment Claims Dismissed, as Time-Barred, Against Former ABC Producer Michael Corn
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In Pachura v. Lloyd J. Austin, III, Secretary, Department of Defense, 6:21-CV-0316 (LEK/ATB), 2022 WL 1909546 (N.D.N.Y. June 3, 2022), the court denied defendant’s motion to dismiss plaintiff’s hostile work environment sexual harassment claim asserted under Title VII of the Civil Rights Act of 1964. The court summarized plaintiff’s allegations, in sum, as follows: Between…

Read More Sexual Harassment Claim Survives Dismissal; Allegations Included Harassment by Facebook Messenger
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In Rodriguez v. Town of Cicero et al, No. 20 C 7608, 2022 WL 1773715 (N.D.Ill. June 1, 2022), the court, inter alia, held that plaintiff sufficiently alleged a hostile work environment sexual harassment claim under Title VII of the Civil Rights Act of 1964. The court summarized plaintiff’s sexual harassment allegations as follows: The…

Read More Police Officer’s Title VII Hostile Work Environment Sexual Harassment Claim Sufficiently Alleged, Court Holds
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In Logan v. Millstone Manor LLC et al, 20-14433 (MAS) (TJB), 2022 WL 1720172 (D.N.J. May 27, 2022), the court, inter alia, dismissed plaintiff’s hostile work environment sexual harassment claim. (The court also dismissed plaintiff’s “quid pro quo” sexual harassment claim.) From the decision: Viewing the evidence in a light most favorable to Logan, his…

Read More Hostile Work Environment Sexual Harassment Claim Dismissed; “High Bar” Not Met
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In Haughton v. Ja-Co Foods, Inc. d/b/a Sonic Drive-Ins, No. 1:20-CV-241-SA-DAS, 2022 WL 1498107 (N.D. Miss. May 11, 2022), the court held that plaintiff presented sufficient evidence to survive summary judgment on plaintiff’s hostile work sexual harassment claim asserted under Title VII of the Civil Rights Act of 1964. Generally, in order to make out…

Read More Title VII Hostile Work Environment Sexual Harassment Claim Survives Summary Judgment; Evidence Included Singing “Inappropriate Songs” and “Humping”
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In Díaz-Zayas v. Municipality of Guaynabo, et al, No. 18-1668 (RAM), 2022 WL 1322657 (D.Puerto Rico April 27, 2022), the court, inter alia, denied defendant’s Rule 12(b)(6) motion to dismiss plaintiff’s quid pro quo sexual harassment claim asserted under Title VII of the Civil Rights Act of 1964. The court summarized the factual allegations, in part, as…

Read More Quid Pro Quo Sexual Harassment Claim, Based on Alleged Conduct of Héctor O’Neill-García, Survives Dismissal
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In Howard et al v. Cook County Sheriff’s Office et al, No. 17 C 8146, 2022 WL 1404833 (N.D.Ill. May 4, 2022), the court held that plaintiffs – female corrections officers – presented enough evidence to overcome defendants’ motion for summary judgment on their claims of hostile work environment sexual harassment (by detainees) under Title…

Read More Jail Employees’ Hostile Work Environment Sexual Harassment Claims Survive Summary Judgment
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In Cruse v. Bi-State Development Agency of Missouri-Illinois Metropolitan District, No. 4:20-cv-366-MTS, 2022 WL 1185149 (E.D.Mo. April 21, 2022), the court, inter alia, held that factual issues precluded summary judgment on plaintiff’s claims of sexual harassment. In sum, plaintiff alleged that her supervisor (Brew) sexually harassed her, both in person and by phone, and that…

Read More Sexual Harassment Claim(s) Survive Summary Judgment; Factual Issues Existed as to Whether Harassment Culminated in a “Tangible Employment Action” Etc.
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