March 2024 - Parks and Recreation - 28

In the case of Achee v. Inc. Village
LAW REVIEW
of Valley Stream, Plaintiff Jahbaree
Achee sued his former employer,
alleging a hostile work environment,
discrimination and retaliation.
Fired Parks Worker Claims
Racial Discrimination
By James C. Kozlowski, J.D., Ph.D.
I
n the case of Achee v. Inc. Village of Valley Stream, 2023 U.S. Dist. LEXIS
194342 (E.D. N.Y. 10/23/2023), Plaintiff Jahbaree Achee sued the
Defendants Incorporated Village of Valley Stream and the Village of
Valley Stream Parks and Recreation Department, alleging a hostile
work environment, discrimination and retaliation in violation of federal
civil rights law Title VII; 42 U.S.C. § 1981.
Facts of the Case
In June of 2014, Plaintiff began
working for the Village of Valley
Stream (the Village) as a seasonal
laborer in the parks department.
Plaintiff identifies as a Jewish African
American male. On Plaintiff's
first day of work, one of his coworkers
informed Plaintiff that another
coworker, " RR, " had called Plaintiff
a " [racial slur]. " In a separate
incident approximately two weeks
later, RR approached Plaintiff and
" yelled multiple racial slurs at him,
including 'stinking
[racial
slur].' "
After this incident, RR continued to
make racially discriminatory comments,
telling Plaintiff that " [Racial
slur] cannot perform the job " and
questioning him about why he was
working for Valley Stream.
In July 2015, Plaintiff changed
roles from a seasonal to a part-time
worker. Plaintiff stated that, after his
transition to a part-time worker, RR
continued to make racially charged
28 Parks & Recreation | MARCH 2 0 2 4 | PARK S ANDRECRE AT ION . OR G
statements to him. In 2016, these
comments escalated to threats against
Plaintiff and that RR said, " Hang
that [racial slur] in the creek bed " in
reference to Plaintiff in front of other
coworkers. In total, Plaintiff estimates
that RR used the word " [a racial slur] "
more than 10 times during the course
of the five years that Plaintiff was
employed by the parks department.
Throughout his employment with the
Village, Plaintiff had two supervisors,
" FT " and " LW. "
In his deposition, Plaintiff further
stated he had told his supervisor FT
that RR " was saying a lot of racial
slurs " and was making him " feel uncomfortable, "
and, in response, FT
told him not to mind RR and " just
shrugged it off and walked away. "
In addition, Plaintiff claimed he
had spoken with both FT and supervisor
LW about the second incident
with RR, and they told him to " forget
about what happened. "
In the summer of 2018, Plaintiff
stated another coworker, " FC, "

March 2024 - Parks and Recreation

Table of Contents for the Digital Edition of March 2024 - Parks and Recreation

March 2024 - Parks and Recreation - Intro
March 2024 - Parks and Recreation - Cover1
March 2024 - Parks and Recreation - Cover2
March 2024 - Parks and Recreation - 1
March 2024 - Parks and Recreation - 2
March 2024 - Parks and Recreation - 3
March 2024 - Parks and Recreation - 4
March 2024 - Parks and Recreation - 5
March 2024 - Parks and Recreation - 6
March 2024 - Parks and Recreation - 7
March 2024 - Parks and Recreation - 8
March 2024 - Parks and Recreation - 9
March 2024 - Parks and Recreation - 10
March 2024 - Parks and Recreation - 11
March 2024 - Parks and Recreation - 12
March 2024 - Parks and Recreation - 13
March 2024 - Parks and Recreation - 14
March 2024 - Parks and Recreation - 15
March 2024 - Parks and Recreation - 16
March 2024 - Parks and Recreation - 17
March 2024 - Parks and Recreation - 18
March 2024 - Parks and Recreation - 19
March 2024 - Parks and Recreation - 20
March 2024 - Parks and Recreation - 21
March 2024 - Parks and Recreation - 22
March 2024 - Parks and Recreation - 23
March 2024 - Parks and Recreation - 24
March 2024 - Parks and Recreation - 25
March 2024 - Parks and Recreation - 26
March 2024 - Parks and Recreation - 27
March 2024 - Parks and Recreation - 28
March 2024 - Parks and Recreation - 29
March 2024 - Parks and Recreation - 30
March 2024 - Parks and Recreation - 31
March 2024 - Parks and Recreation - 32
March 2024 - Parks and Recreation - 33
March 2024 - Parks and Recreation - 34
March 2024 - Parks and Recreation - 35
March 2024 - Parks and Recreation - 36
March 2024 - Parks and Recreation - 37
March 2024 - Parks and Recreation - 38
March 2024 - Parks and Recreation - 39
March 2024 - Parks and Recreation - 40
March 2024 - Parks and Recreation - 41
March 2024 - Parks and Recreation - 42
March 2024 - Parks and Recreation - 43
March 2024 - Parks and Recreation - 44
March 2024 - Parks and Recreation - 45
March 2024 - Parks and Recreation - 46
March 2024 - Parks and Recreation - 47
March 2024 - Parks and Recreation - 48
March 2024 - Parks and Recreation - 49
March 2024 - Parks and Recreation - 50
March 2024 - Parks and Recreation - 51
March 2024 - Parks and Recreation - 52
March 2024 - Parks and Recreation - 53
March 2024 - Parks and Recreation - 54
March 2024 - Parks and Recreation - 55
March 2024 - Parks and Recreation - 56
March 2024 - Parks and Recreation - Cover3
March 2024 - Parks and Recreation - Cover4
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/august-2024
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/july-2024
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/june-2024
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/may-2024
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/april-2024
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/march-2024
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/february-2024
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/january-2024
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/december-2023
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/november-2023
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/october-2023
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/september-2023
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/august-2023
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/july-2023
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/june-2023
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/may-2023
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/april-2023
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/march-2023
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/february-2023
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/january-2023
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/december-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/november-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/october-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/september-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/august-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/july-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/june-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/may-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/april-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/march-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/february-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/january-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/december-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/november-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/october-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/september-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/august-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/july-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/june-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/may-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/april-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/march-2021
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