The New York City Commission on Human Rights is seemingly ramping up its restrictions on employers with a new Legal Enforcement Guidance on certain protections in the NYC Human Rights Law (NYCHRL). Specifically, a new guidance released this month provides that employers (as well as landlords) could be subjected to fines up to $250,000 for such speech as threatening to call Immigration and Customs Enforcement on an illegal alien – or in fact, for even referring to an illegal alien as well, an illegal alien! Publication of the new guidance follows the decision of a NYC administrative law judge in a landlord-tenant dispute where the landlord was fined $17,000 for threatening to call ICE on the tenant, who was not legally in the US and owed $14,000 in back rent.  The guidance specifically states that “harassment related to immigration status or national origin in the workplace covers a broad range of conduct and generally occurs when an individual is treated less well on account of their actual or perceived immigration status.”