Queens Jury Awards $3.65M in Hotel Sexual Harassment Case Against Mayflower Hotel

A federal jury in the Eastern District of New York awarded $3.65 million to former assistant manager Jeannette Figueroa after finding liability on hostile work environment claims under New York State Human Rights Law and New York City Human Rights Law. The verdict assigns $1.65 million in compensatory damages and $2 million in punitive damages against entities operating as Mayflower Hotel. The panel concluded the hotel failed to respond adequately to reports that residents at a city‑contracted shelter site engaged in repeated harassment and violence toward Figueroa.

Factual Background

Figueroa began work in April 2021 at a Howard Johnson in Long Island City operated by Mayflower Hotel. The property functioned as a shelter under a city contract. According to court filings, Figueroa reported frequent catcalling and sexual comments by residents over a five‑month period. She alleged physical assaults as well. In one April 2021 incident, a resident struck her with a Wet Floor sign, later made romantic advances, and attempted to accompany her after her shift. In June 2021, another resident threw a picnic table that struck Figueroa and knocked her unconscious. The complaint alleges security staff minimized the event and management did not compensate her for the injury. She reported residents directing sexual innuendo and derogatory names at her and acting inappropriately with cleaning staff, which required her intervention. After she requested a transfer and was told none was available, she resigned citing safety concerns.

Claims and Defenses

Figueroa alleged a hostile work environment under state and city laws and claimed the hotel failed to take reasonable corrective action once on notice of third‑party harassment and assaults. The case centered on employer responsibility when harassment is committed by nonemployees such as residents or customers in a shelter‑hotel setting. Defendants argued the city controlled management and security at the site and that the hotel lacked authority over residents’ conduct. The jury rejected that position and held the hotel responsible for failing to address ongoing risks that affected conditions of employment.

Plaintiff’s counsel framed the verdict as a compliance signal for shelter operators. “This verdict sends a clear message that employers operating shelter sites cannot abdicate responsibility for the safety of their staff,” the attorney said in a statement. Counsel added, “Ms. Figueroa endured one of the worst‑case scenarios: instances of violent assaults that rendered her disabled, and sexual harassment and abuse.”

Legal Standards Under NYSHRL and NYCHRL

Under New York State and City human rights laws, employers may be liable for harassment by nonemployees when the employer knew or should have known about the conduct and failed to take immediate and appropriate corrective action. The city law applies a broader construction that favors plaintiffs and does not require conduct to be severe or pervasive to the same degree as federal law. Juries may consider whether management received credible reports, whether response protocols existed, and whether remedial steps were timely and effective. In a shelter‑hotel context, those steps can include incident logging, staffing adjustments, security measures, warnings, removal procedures consistent with contract terms, and employee support such as medical evaluation and paid leave.

The verdict indicates the jury found that notice and failure to act were established. The presence of a municipal contract does not eliminate an employer’s duty to protect employees from known risks within the workplace. Jurors likely focused on repeated reports, escalation from verbal harassment to physical injury, and the absence of effective corrective action.

Damages and Punitive Award

The compensatory award of $1.65 million reflects physical injury, emotional distress, and harm to employment conditions. New York juries may award damages for pain and suffering and reputational or career impacts when supported by testimony and records. The $2 million punitive award signals a finding that the defendants’ conduct warranted punishment and deterrence under applicable law. Punitive damages in employment cases turn on proof of willful or reckless disregard of protected rights.

For employers, the damages profile underscores exposure beyond back pay. Emotional distress and other non‑economic damages can dominate the recovery when harassment is persistent or violent. Punitive exposure rises where complaints are ignored or minimized, where safety complaints recur, or where corrective steps are delayed despite clear notice.

Employer Liability for Third‑Party Harassment in Shelter Hotels

Shelter hotels sit at the intersection of hospitality operations and public services. They also present atypical risk vectors because guests or residents may not be subject to ordinary guest removal processes. Effective compliance requires clear escalation pathways owned jointly by site leadership, human resources, and contracted partners. Written protocols should define when to separate the employee from the source of harassment, when to engage law enforcement, and when to seek removal or reassignment consistent with the governing contract.

Security planning is central. Site‑specific risk assessments, staffing models, and post orders help ensure rapid response to escalating behavior. Independent reviews by security professionals can stress‑test surveillance coverage, staffing ratios, and incident reporting loops. Where employees suffer injuries on the property, companies should anticipate claims that overlap workplace safety and premises liability. Coordinated documentation across incident logs, HR files, and security reports often determines how a jury evaluates notice, response time, and the effectiveness of corrective actions.

What Comes Next

Post‑verdict practice may include motions under Federal Rules of Civil Procedure 50 and 59 seeking judgment as a matter of law, a new trial, or remittitur. Appellate issues can include sufficiency of evidence on notice, employer control, and punitive damages standards under the state and city laws. Unless altered by the court, the verdict sets a reference point for damages in third‑party harassment cases arising from shelter operations and similar hybrid settings.

Practical Implications

Employers that host shelter populations or operate long‑term stay properties should audit incident intake and response. Critical elements include rapid supervisor escalation, documented follow‑through, medical evaluation after any physical incident, and timely consideration of transfer or paid leave when safety risks persist. Contracts with public entities should define security responsibilities and removal procedures with precision. Training must ensure front‑line staff know when to involve management and when to prioritize personal safety. Documented action, not policy on paper, will be the focus if litigation occurs.

Case Details

Case Name: Figueroa v. Mayflower International Hotel Group Inc. et al.
Court Name: (U.S. District Court for the Eastern District of New York)
Case Number: 1:23-cv-04729
Plaintiff Attorney(s): Troy Law PLLC
Defense Attorney(s): Kevin Kerveng Tung PC