What is the need to plead discriminatory animus for both age discrimination and hostile work environment?

"New York", United States of America

The following excerpt is from Foley v. State, 43 N.Y.S.3d 767 (Table) (N.Y. Ct. Cl. 2016):

4 On the need to show (or plead) discriminatory animus for both age discrimination and hostile work environment, see Massaro v. Department of Educ. of the City of NY, 121 AD3d 569 (1st Dept 2014), lv. denied 26 NY3d 903 (2015).

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