Siddiqui v. NY City Health and Hosp. Corp. (S.D.N.Y. 2008): Failed Discrimination Claim

A Pakistani Muslim hospital employee sued his employer under Title VII, New York State Human Rights Law, and New York City Human Rights Law (after receiving a right to sue letter from the Equal Employment Opportunities Commission (EEOC)), alleging discrimination based on race, religion, and national origin and a hostile work environment. The plaintiff argued that he received negative performance evaluations because he was absent from work on several Fridays and other days in observance of Islamic religious prayer services and holidays, in compliance with Islamic ritual law. The Court concluded that the plaintiff failed to make out a prima facie discrimination claim, as he never articulated any adverse employment action suffered. The Court, however, allowed Plaintiff’s hostile work environment claim to move forward as it raised a material question of fact that should be decided by a jury. 

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