Hostile Work Environment

In Mejia v T.N. 888 Eighth Ave. LLC Co., the Appellate Division First Department affirmed summary judgment for the employer, applying the Continuing Violations doctrine, because according to the court, the employee failed to testify or put forward other evidence of the dates of the alleged harassment within the 3-year statute of limitations period applicable…

Read More Appellate Division Affirms Summary Judgment For Cosmic Diner, Applying Continuing Violations Doctrine, Where Employee Failed to Present Any Specific Instances of Harassment Within Statute of Limitations Period

New York’s highest court–the New York Court of Appeals–held in Zakrzewska v New School that the Faragher-Ellerth defense does not apply to claims brought under the New York City Human Rights Law. The Faragher-Ellerth defense provides as follows: “an employer is not liable under Title VII for sexual harassment committed by a supervisory employee if it sustains the…

Read More Faragher-Ellerth Defense Does Not Apply to Claims Brought Under the New York City Human Rights Law, Court Says