A New York federal district court granted summary judgment to New York Spine & Sport Rehabilitation Medicine on a female physician’s Title VII of the Civil Rights Act hostile work environment and retaliation claims, finding the claims time-barred because the constructive discharge accrued when she gave notice of resignation—outside the 300-day limitations period—and, alternatively, that the few isolated incidents over four years were insufficient to establish a sex-based hostile work environment under the McDonnell Douglas framework.
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