Plaintiff, a white woman, alleges race discrimination by her former employer, the New York City Department of Education.

Plaintiff alleges that Defendant adopted a "race-based policy" making race a determinative factor in employment decisions, and required employers like her to attend implicit bias trainings and meetings, which together constituted race discrimination in violation of section 1983.

The district court dismissed Plaintiff's claim, finding that Defendant had legitimate and non-discriminatory reasons for adverse actions taken toward her. It further held that there was insufficient evidence to support a finding that the Department had a policy to make race a determinative factor in employment decisions. The court also found that there was no evidence from which a jury could find that Defendant's implicit bias training created a hostile work environment.

Plaintiff appealed this decision.

On September 25, 2025, the court of appeals agreed with the district court's decision to grant summary judgment to Defendant on Plaintiff's demotion and constructive discharge claims. However, the court of appeals vacated the district court's decision to grant summary judgment on Plaintiff's hostile work environment claim. The court of appeals held that there are genuine disputes of material fact that prevent the granting of summary judgment on the hostile work environment claim. The court found that a rational jury could find that racist comments were expressed during bias trainings and that Plaintiff was repeatedly exposed to racial harassment at her workplace throughout 2018 and 2019. Additionally, Plaintiff was able to provide sufficient evidence that Defendant knew about the racial harassment but consistently failed to intervene. The case was sent back to the lower court for further proceedings.