In King v. Aramark Services, Inc., No. 22-1237 (March 20, 2024), a Second Circuit panel affirmed the dismissal of claims under the New York State Human Rights Law (“NYSHRL”), concluding that under New York’s “impact test,” occasional remote work by an employee within the state is insufficient to render New York “the place where the impact of the alleged discriminatory conduct is felt” for purposes of coverage under the NYSHRL.
However, the court permitted plaintiff’s hostile work environment claim under Title VII of the Civil Rights Act of 1964 (“Title VII”) to proceed, holding that a discrete discriminatory act within the statute of limitations period may render a hostile work environment claim timely if part of the course of discriminatory conduct underlying the claim.
