Hostile work environment claim can be brought by employee outside of victimized group.

The plaintiff, a male, alleged that his termination stemmed from his complaints about inappropriate comments made in his presence about women but not involving or directed at him. In affirming the validity of the plaintiff’s cause of action, the New Jersey Supreme court concluded that a plaintiff need not be a victim of the hostile work environment but need only show a good faith belief that the complained of conduct violated the NJLAD. Further, the court also held that a claim for future emotional distress must be supported by competent medical evidence of permanency.

Case Law Alerts, 4th Quarter 2013