Scott v. City of New York Department of Correction

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• explaining that facts and theories raised for the first time in opposition papers should not be considered in resolving a summary judgment motion
• declining to consider claims not pleaded in pro se complaint, but raised for the first time in opposition to summary judgment
• “Negative comments ... are not, standing alone, adverse employment actions, because mere comments do not materially affect employment.”
• “[V]erbal abuse is typically insufficient to constitute an adverse employment action because negative or otherwise insulting statements are hardly even actions, let alone adverse actions.

Source: CourtListener parenthetical corpus (CC0).