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8 New York opinions name it 3 courts 2012–2025 3 in the last five years
The cases below were cited by New York courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Forrest v. Jewish Guild for the Blindgreen2 sentences2020To set forth an unlawful retaliation claim, an employee must show that "(1) [he or] she has engaged in protected activity, (2) [his or] her employer was aware that [he or] she participated in such activity, (3) [he or] she suffered an adverse employment action based upon [his or] her activity, and (4) there is a causal connection between the protected activity and the adverse action" ( Forrest v Jewish Guild for the Blind , 3 NY3d 295, 313 ; see Ruane-Wilkens v Board of Educ. of City of N.Y. , 56 AD3d 648 , 649). 2019We also agree with the Supreme Court's determination to grant those branches of the defendants' separate motions which were for summary judgment dismissing the seventh cause of action, alleging retaliation under the NYCHRL. "[T]o make out an unlawful retaliation claim under the NYCHRL, a plaintiff must show that (1) he or she engaged in a protected activity as that term is defined under the NYCHRL, (2) his or her employer was aware that he or she participated [*3]in such activity, (3) his or her employer engaged in conduct which was reasonably likely to deter a person from engaging in that pro | 4 | 5 |
Brightman v. Prison Health Service, Inc.green2 sentences2025NO. 868 RECEIVED NYSCEF: 05/16/2025 acts complained of must be reasonably likely to deter a person from engaging in protected activity.” Hence, “‘to make out an unlawful retaliation claim under the NYCHRL, a plaintiff must show that (1) he or she engaged in a protected activity as that term is defined under the NYCHRL, (2) his or her employer was aware that he or she participated in such activity, (3) his or her employer engaged in conduct which was reasonably likely to deter a person from engaging in that protected activity, and (4) there is a causal connection between the protected activity 2025USA, Inc. , 112 AD3d at 806). " '[T]o make out an unlawful retaliation claim under the NYCHRL, a plaintiff must show [*4]that (1) he or she engaged in a protected activity as that term is defined under the NYCHRL, (2) his or her employer was aware that he or she participated in such activity, (3) his or her employer engaged in conduct which was reasonably likely to deter a person from engaging in that protected activity, and (4) there is a causal connection between the protected activity and the alleged retaliatory conduct' " ( Sanderson-Burgess v City of New York , 173 AD3d 1233 , 1235-1236 [ | 2 | 5 |
Reichman v. City of New Yorkgreen2 sentences2025"To establish its entitlement to summary judgment in a retaliation case [under . . . (the) NYCHRL], a defendant must demonstrate that the plaintiff cannot make out a prima facie claim of retaliation or, having offered legitimate, nonretaliatory reasons for the challenged actions, that there exists no triable issue of fact as to whether the defendant's explanations were pretextual" ( Reichman v City of New York , 179 AD3d 1115, 1119-1120 [2020] [internal quotation marks omitted]; see Delrio v City of New York , 91 AD3d 900, 901 [2012]). 2021The NYCHRL offers retaliation victims, like discrimination victims, broader protection than its NYSHRL counterpart ( see Reichman v City of New York , 179 AD3d at 1119 ; Brightman v Prison Health Serv., Inc. , 108 AD3d 739, 740 ). "'[T]o make out an unlawful retaliation claim under the NYCHRL, a plaintiff must show that (1) he or she engaged in a protected activity as that term is defined under the NYCHRL, (2) his or her employer was aware that he or she participated in such activity, (3) his or her employer engaged in conduct which was reasonably likely to deter a person from engaging in that | 2 | 2 |
Delrio v. City of New Yorkgreen2 sentences2025"To establish its entitlement to summary judgment in a retaliation case [under . . . (the) NYCHRL], a defendant must demonstrate that the plaintiff cannot make out a prima facie claim of retaliation or, having offered legitimate, nonretaliatory reasons for the challenged actions, that there exists no triable issue of fact as to whether the defendant's explanations were pretextual" ( Reichman v City of New York , 179 AD3d 1115, 1119-1120 [2020] [internal quotation marks omitted]; see Delrio v City of New York , 91 AD3d 900, 901 [2012]). 2013Once the plaintiff has met this initial burden, the burden then shifts to the defendant to present legitimate, independent, and nondiscriminatory reasons to support its actions (see Delrio v City of New York, 91 AD3d at 901 ). | 1 | 2 |
Bilitch v. New York City Health & Hosps. Corp.green1 sentence2025Corp., 194 AD3d 999, 1004 [2d Dept 2021]). | 1 | 1 |
Reyes v. Brinks Global Services USA, Inc.green1 sentence2025USA, Inc. , 112 AD3d at 806). " '[T]o make out an unlawful retaliation claim under the NYCHRL, a plaintiff must show [*4]that (1) he or she engaged in a protected activity as that term is defined under the NYCHRL, (2) his or her employer was aware that he or she participated in such activity, (3) his or her employer engaged in conduct which was reasonably likely to deter a person from engaging in that protected activity, and (4) there is a causal connection between the protected activity and the alleged retaliatory conduct' " ( Sanderson-Burgess v City of New York , 173 AD3d 1233 , 1235-1236 [ | 1 | 1 |
Bendeck v. NYU Hospitals Centergreen1 sentence2012Ctr., 77 AD3d 552, 553 [2010]; see also Reed v A.W. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in New York. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Keceli v. Yonkers Racing Corp.
green
1 sentence2021"To establish its entitlement to summary judgment in a retaliation case [under either the NYSHRL or the NYCHRL], a defendant must demonstrate that the plaintiff cannot make out a prima facie claim of retaliation or, having offered legitimate, nonretaliatory reasons for the challenged actions, that there exists no triable issue of fact as to whether the defendant's explanations were pretextual" ( Reichman v City of New York , 179 AD3d at 1119-1120 [internal quotation marks omitted]; see Forrest v Jewish Guild for the Blind , 3 NY3d at 305 ; Keceli v Yonkers Racing Corp. , 155 AD3d at 1016 ; La | 1 | 2021–2021 |
La Marca-Pagano v. Dr. Steven Phillips, P.C.
green
1 sentence2021"To establish its entitlement to summary judgment in a retaliation case [under either the NYSHRL or the NYCHRL], a defendant must demonstrate that the plaintiff cannot make out a prima facie claim of retaliation or, having offered legitimate, nonretaliatory reasons for the challenged actions, that there exists no triable issue of fact as to whether the defendant's explanations were pretextual" ( Reichman v City of New York , 179 AD3d at 1119-1120 [internal quotation marks omitted]; see Forrest v Jewish Guild for the Blind , 3 NY3d at 305 ; Keceli v Yonkers Racing Corp. , 155 AD3d at 1016 ; La | 1 | 2021–2021 |
Albunio v. City of New York
green
1 sentence2020The NYCHRL offers retaliation victims, like discrimination victims, broader protection than its NYSHRL counterpart ( see Albunio v City of New York , 16 NY3d 472, 477-478 ; Brightman v Prison Health Serv., Inc. , 108 AD3d at 740 ). " [T]o make out an unlawful retaliation claim under the NYCHRL, a plaintiff must show that (1) he or she engaged in a protected activity as that term is defined under the NYCHRL, (2) his or her employer was aware that he or she participated in such activity, (3) his or her employer engaged in conduct which was reasonably likely to deter a person from engaging in tha | 1 | 2020–2020 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.