Matter of Rensselaer County Sheriff's Department v. New York State Division of Human Rights
Lora Abbott Seabury, an employee at a correctional facility, filed a complaint in 2010 alleging sexual harassment by male coworkers, creating a hostile work environment. An Administrative Law Judge found in her favor, recommending substantial economic and non-economic damages. The Commissioner of Human Rights adjusted the economic damages but adopted the recommendations. The correctional facility (petitioner) sought to annul the determination, while Seabury sought modification and confirmation. The Court upheld the finding of a hostile work environment due to gender-based harassment, crediting Seabury's testimony about daily harassment, supervisors' inaction, and gender-biased statements. The Court also affirmed the $300,000 award for noneconomic injuries, finding it supported by evidence of severe psychological trauma, including PTSD and major depressive disorder. Furthermore, the Court ruled that Seabury's award should not be offset by workers' compensation benefits and that pension losses must be compensated, remitting the matter to determine those damages.