The New Jersey Appellate Division held that a former Rutgers master's student failed to demonstrate a prima facie claim of hostile educational environment based on a disability or perceived disability under the New Jersey Law Against Discrimination.

Kingsley Okituamah, a Black man of African descent, appealed the dismissal of his claim filed against Rutgers, The State University of New Jersey, where he earned a master of science degree in global affairs from Rutgers in January 2018. Okituamah alleged that, while enrolled in defendant Richard O'Meara's international law course, he was harassed and intimidated by the professor because of his race and mental illness, according to the opinion.

The unpublished decision in Okituamah v. O'Meara, concluded that Okituamah failed to satisfy the elements of a hostile educational environment under the NJLAD and affirmed the Essex County Superior Court's order dismissing his complaint against Rutgers, according to the per curiam opinion by Judges Lisa Rose and Katie A. Gummer.