Onanuga v. Huntington Life Sciences, Inc., No. A-5743-08T1 (App. Div., May 19, 2010) – The Appellate Division rejected an employee’s claim that his employer discriminated against him by requiring him to do extra work based upon greater proficiency in English than other employees. The court held that “[w]ithout more, assigning work based on language skills is not discrimination,” but stated a different result might occur if a plaintiff can demonstrate that the employer’s action was simply a proxy for discrimination. The court further rejected the plaintiff’s hostile work environment claim based upon an alleged disagreement with his supervisor in which she yelled at him, because “personality conflicts” and “insults” alone do not violate the NJLAD.