A New York federal district court partially denied Service Employees International Union, Local 32BJ’s motion to dismiss retaliation claims under Section 1981, the New York State Human Rights Law, the New York City Human Rights Law, and Title VII of the Civil Rights Act brought by a pro se female employee, finding that she sufficiently alleged a causal link between her protected activity of filing a discrimination lawsuit and adverse actions by the union, including failing to pursue her grievances while her lawsuit was pending and removing her name from voter rolls in a union election.
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