Williams v. New York City Housing Authority, 61 A.D.3d 62 (1st Dep’t 2009)

Williams v. New York City Housing Authority, 61 A.D.3d 62 (1st Dep’t 2009) established that the legal standard in New York City is not whether the harassing conduct was “severe or pervasive” but when looking at how someone is treated has that person been treated “less well” because of their gender. Thus, under the New York City Human Rights Law, conduct need not be “severe or pervasive” to constitute a hostile work environment, but instead the analysis is one of differential treatment and whether a victim has been treated “less well” than other employees in the workplace due to gender. In New York City a violation is defined as more than “petty slights and trivial inconveniences.” This standard was adopted into New York state law in 2019.