Statute Annotations › Federal › 42 U.S.C. § 2000e-2

42 U.S.C. § 2000e-2

Unlawful employment practices: the cases that interpreted this section

Jurisdiction
Federal
Case notes
12,593
Cited in passing
5,373
Citing cases indexed
23,155
Case dates
1966–2026
Screened through
2026-01-28
Courts' treatment: live
No reviewed case has held this section invalid, preempted, superseded or repealed.
This reflects what the reviewed cases said, not legislative action: a later amendment or repeal by the legislature would not appear here unless a reviewed case discussed it.

17,966 citing cases reviewed of 23,155 in the citation index: 12,593 interpreted the section (annotated below), 5,373 cited it only in passing. Cases filed after 2026-01-28 may not have been reviewed yet.

Have a situation under 42 U.S.C. § 2000e-2?

These notes show how courts have ruled. Ask about your specific facts and see which of these rulings apply, with citations you can check.

Hostile work environment

A supervisor’s awareness of racial harassment can give an employer actual notice of a hostile work environment even if the employee does not report it.

Smelter v. Souther Home Care Services Inc. · filed 2018-09-24(a)(1)

The record thus contains evidence that Talton had actual notice of the hostile work environment despite Smelter’s failure to report it. And because Talton was Smelter’s supervisor, we can impute Talton’s notice to Southern Home. See Miller, 277 F.3d at 1278.
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Section 2000e-2 covers a sex-based hostile work environment when discriminatory conduct is sufficiently severe or pervasive to alter employment conditions.

Cunningham v. Mylan Pharmaceuticlals, Inc. · filed 2018-09-29

Moreover, the allegations are sufficient to support a finding that she was subjected to discriminatory conduct “sufficiently severe or pervasive to alter the conditions of [her] employment.” Ayissi–Etoh, 712 F.3d at 577 (citation omitted).
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Section 2000e-2(a) requires a race-based hostile work environment claim to allege sufficiently severe or pervasive mistreatment; two disciplinary incidents and a conclusory allegation of unequal discipline did not suffice.

Wesley v. Georgetown University · filed 2018-11-02(a)

These examples, together with his conclusory statement that “Hispanic employees are not subject to the same disciplinary measures as non-Hispanics,” id. ¶ 12, are neither pervasive enough nor adverse enough to give rise to a hostile work environment claim.
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Section 2000e-2 requires hostile work environment harassment to be based on race or another protected status; a jury may infer racial motive from a supervisor's workplace slurs and mistreatment.

Lindsay-Felton v. FQSR, LLC · filed 2018-11-07

Considering such evidence in a light most favorable to Plaintiff, the Court finds that there is sufficient evidence in the record for a reasonable juror to conclude that Shue's mistreatment of Plaintiff occurred as a result of her race.
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A race-based hostile work environment claim under § 2000e-2 fails without evidence that race caused the harassment.

Gaston v. Board Of Education Of The City Of Chicago · filed 2019-01-31

Gaston therefore failed to proffer sufficient evidence to demonstrate that her race was the cause of her harassment.
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A resident’s mental condition does not bar a caregiver’s hostile work environment claim when a jury could find the resident’s repeated physical harassment severe or pervasive.

Gardner v. CLC of Pascagoula, L.L.C. · filed 2019-02-06(a)(1)

A jury could conclude that an objectively reasonable caregiver would not expect a patient to grope her daily, injure her so badly she could not work for three months, and have her complaints met with laughter and dismissal by the administration.
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Section 2000e-2(a) permits a sex-based hostile work environment claim when a rumor that a woman slept with her boss to gain promotion reflects gender stereotypes and the resulting harassment is severe or pervasive.

Parker v. Reema Consulting Services, Inc · filed 2019-02-08(a)

Accordingly, because Parker’s complaint plausibly alleges a hostile work environment claim under Title VII for discrimination because of sex, we reverse the district court’s ruling dismissing Count I.
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Section 2000e-2(a) treats a racially hostile work environment as an unlawful employment practice; a plaintiff need not show that the workplace was “hellish.”

Gates v. Bd. of Educ. of Chi. · filed 2019-02-20(a)

Subjecting an employee to a hostile work environment counts as an adverse action ("unlawful employment practice") within the meaning of Title VII's prohibition of race discrimination in 42 U.S.C. § 2000e-2(a). ... While a "hellish" workplace is surely actionable, plaintiffs' evidence need not show a descent into the Inferno.
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Section 2000e-2(a)(1) prohibits sex-based hostile work environments when harassment is sufficiently severe or pervasive to alter the conditions of employment.

Martinelli v. Bancroft Chophouse, LLC · filed 2019-02-22(a)(1)

Assuming arguendo that Martinelli is a member of a protected class and was subjected to sexual harassment, he has failed to demonstrate that the alleged harassment was sufficiently severe or pervasive to prevail on his claim for hostile work environment.
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Section 2000e-2(a)(1) discrimination claims require an adverse employment action, and hostile work environment claims require allegations linking the abuse to a protected class.

Sosa v. N.Y.C. Dep't of Educ. & Marcy Berger · filed 2019-03-25(a)(1)

Therefore, these Title VII claims-Counts 4 through 6-must be dismissed for the same reasons as those described above: the unlawful discrimination claims fail to allege an adverse employment action; the disparate treatment allegations-with respect to whether other employees are similarly situated-fail to create an inference of discrimination; and the hostile work environment allegations fail to allege in a non-conclusory fashion that the abusive environment was because of Sosa's membership in a protected class.
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Section 2000e-2(a)(1) requires a plaintiff alleging a sex-based hostile work environment to show that the harassment occurred because of sex.

Panagiota Heath v. Southern University System Fdn · filed 2019-04-01(a)(1)

Though Heath’s factual allegations suggest that her workplace was indeed ... unpleasant, we agree with the magistrate judge’s conclusion that she has failed to demonstrate that Elaasar’s alleged harassment was motivated by her sex.
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Section 2000e-2(a)(1) does not reach infrequent racist comments that do not create a racially hostile work environment.

Irani v. Palmetto Health · filed 2019-04-10(a)(1)

Rather, the comments are more akin to the “simple teasing” and “offhand comments” that Title VII does not reach.
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Section 2000e-2(a)(1) covers sexual harassment that creates a hostile work environment, and an employee's apparent participation does not necessarily mean the conduct was welcome.

Chesier v. On Q Fin. Inc. · filed 2019-04-18(a)(1)

A plaintiff may appear to participate in sexual conduct without necessarily welcoming that conduct.
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An employer that promptly removes and investigates an alleged harasser can satisfy its duty to take action reasonably calculated to end the harassment.

Jackson v. Kan. City Kan. Pub. Sch. Unified Sch. Dist. No. 500 · filed 2019-05-03(a)

No reasonable jury could find defendant failed to take responsive action that was "reasonably calculated to end the harassment." Adler , 144 F.3d at 676. The court thus concludes that summary judgment is appropriate against plaintiff's sexual harassment claim.
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Sexual harassment must be severe or pervasive enough to be actionable under Title VII.

Rodgers v. North Little Rock School District · filed 2019-05-07(a)(1)

After reviewing the record and drawing all reasonable inferences in favor of Plaintiff, the Court finds that Donaldson’s conduct did not rise to the level of severe or pervasive enough to be actionable under Title VII.
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An adequate remedial response to coworker harassment defeats a Title VII hostile work environment claim against the employer.

Martin v. New York State · filed 2019-05-09(a)(1)

In short, there is no evidence from which a reasonable jury could find that DOCCS acted negligently or that its remedial response was inadequate.
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A single allegation that an employee found a noose does not, by itself, establish a hostile work environment under § 2000e-2(a)(1).

Martin v. Am. Midstream Partners, LP · filed 2019-05-15(a)(1)

Plaintiffs' single allegation that Percy Martin found a noose does not establish a hostile work environment by itself.
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Title VII permits a hostile work environment claim when the employee plausibly alleges sexual harassment.

Semmami v. UG2 LLC · filed 2019-05-24

As noted, the Court concludes that Semmami has stated a viable claim for a hostile work environment in violation of Title VII.
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An employer may be liable for a coworker’s harassment when it knows of the conduct and fails to take remedial action; an employee need not establish every element of a hostile work environment claim when reporting it.

Atkins v. Smyth Cnty. Va. Sch. Bd. · filed 2019-05-29(a)(1)

First, the employer need only know of the harassment for the conduct to be imputed to it; employees are not required to satisfy the elements of a hostile work environment claim when notifying their employers of harassment. Moreover, although the School Board investigated Atkins' written grievance, it failed to take any remedial action, and it failed to investigate or take remedial action in response to Atkins' various verbal complaints regarding Leonard's conduct. Accordingly, Atkins has alleged facts making it plausible that the School Board was negligent in controlling working conditions and thus Leonard's conduct can be imputed to it.
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Section 2000e-2 does not require an explicit sexual solicitation to support a hostile work environment claim.

Miles-Cacella v. International Fellowship of Christians and Jews · filed 2019-06-10(a)(1)

While the complaint may not allege that Mamo explicitly solicited sex, see [10] at 5, there is no requirement that Kennedy make such an allegation.
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Section 2000e-2(a)(1) allows a sex-based hostile work environment claim; when the alleged harasser is a supervisor, the plaintiff need not separately show that the employer knew of the harassment and failed to act.

Garvin v. Sw. Corr., L. L.C. · filed 2019-06-18(a)(1)

When the alleged harasser is a supervisor with immediate or higher authority over the plaintiff, the plaintiff need only meet the first four elements of the test.
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An employer that promptly takes disciplinary action after learning of coworker harassment is not liable for that harassment under Title VII.

Solomon v. Wardlaw Claim Service, LLC · filed 2019-06-19(a)(1)

Wardlaw has satisfied its obligation under Title VII by promptly taking disciplinary action.
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Section 2000e-2(a)(1) permits a hostile work environment claim based on race or sex when discrimination because of that trait alters the conditions of employment.

Allen v. Mnuchin · filed 2019-06-24(a)(1)

Read in the light most favorable to her, Plaintiff’s pleading plausibly suggests that BEP created and sustained a racially discriminatory and gender/sex discriminatory hostile work environment due to its treatment of African-American female employees and due to the manner in which it redressed problematic incidents with Mr. Wilson for African-American women as opposed to white men. This pleading is adequate to survive a Rule 12(b)(6) motion to dismiss, and Defendant’s motion to dismiss Plaintiff’s disparate treatment claim in its entirety as duplicative is therefore denied.
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Section 2000e-2(a)(1) covers workplace harassment when the overall pattern could reasonably be found to be motivated by race, even if some incidents are not explicitly racial.

Vovilla v. Illinois Department of Human Services · filed 2019-07-09(a)(1)

The present record would allow a reasonable jury to find that Vovillia was harassed due to his race.
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Section 2000e-2(a)(1) permits a hostile work environment claim against an employer when alleged threats, comments, and disparate work assignments plausibly amount to sex-based harassment.

Posada v. Acp Facility Servs., Inc. · filed 2019-07-29(a)(1)

Posada has stated a plausible claim for hostile work environment based on the alleged threatening and intimidating conduct of Alvarado and the comments made and disparate work assigned by Ronquillo.
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Section 2000e-2(a)(1) permits an employer to be held liable for a supervisor’s hostile work environment or for a co-worker’s harassment that the employer knew or should have known about.

Posada v. Suarez · filed 2019-07-29(a)(1)

It is a reasonable inference that ACP knew, or should have known, about Alvarado’s misconduct (especially after Posada reported it to her direct supervisor) and thus it is plausible that ACP is liable for Alvarado’s misconduct as a co-worker under both Title VII and Chapter 151B. ACP can also be held vicariously liable under both statutes for the alleged misconduct of Ronquillo as Posada’s supervisor.
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Section 2000e-2 requires a workplace harassment claim to allege harassment based on race, color, religion, sex, or national origin and employer liability.

Martin v. Whittlesea · filed 2019-07-29(a)(1)

To the extent Plaintiff intended to file a Title VII harassment claim, she failed to allege the harassment was based on race, color, religion, sex, or national origin or that her employer was liable for such harassment. The Court, therefore, will dismiss Plaintiff’s complaint with leave to amend.
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Section 2000e-2(a) requires unwelcome harassment severe enough to affect employment conditions for a hostile work environment claim.

Mahler v. First Dakota Title Ltd Partner · filed 2019-07-31(a)

Under Title VII, a hostile work environment claim is a type of discrimination claim under 42 U.S.C. § 2000e-2(a). ... Because her actions demonstrate that she did not personally experience offensive or unwelcome harassment, her claim fails.
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Section 2000e-2(a)(1) requires harassment to be severe or pervasive enough to alter employment conditions for a hostile work environment claim.

Simmons v. Safeway, Inc. · filed 2019-08-01(a)(1)

Even viewing the facts in a light most favorable to the Plaintiff, she has failed to point to sufficient issues of fact that show that Mr. Shaffer's conduct was severe or pervasive enough to alter her conditions of employment from the perspective of a reasonable woman.
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Section 2000e-2(a) requires race-based harassment to be severe or pervasive enough to create an actionable hostile work environment.

Ross v. The University of Chicago · filed 2019-08-05(a)

At the pleading stage, however, Ross has not pled conduct severe or pervasive enough to constitute an actionable hostile work environment as a matter of law or to entitle him to discovery.
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Section 2000e-2(a)(1) permits a hostile work environment claim to consider conduct that is not overtly sexual when a jury could link it to sexual harassment.

Mader v. Lowe's Home Centers, LLC · filed 2019-08-16(a)(1)

Accordingly, the Court concludes that a reasonable juror could determine that there was a connection between the butt grab and the other offending behavior that was not overtly sexual.
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A hostile work environment claim under § 2000e-2(a)(1) requires sexual harassment that is sufficiently severe or pervasive.

Wilson v. Republic National Industries of Texas LP · filed 2019-08-16(a)(1)

However, because of the isolated nature of the comments and the fact that there were only three separate instances alleged, Plaintiff’s allegations fail to allege sufficiently severe or pervasive harassment as viewed from an objective standard to proceed.
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An employer may be liable under § 2000e-2(a)(1) for coworker harassment if it knew of the harassment and failed to take reasonable action to stop it.

Corbin v. Steak N' Shake, Inc. · filed 2019-08-21(a)(1)

A jury could find that defendants acted unreasonably by failing to investigate or take action to prevent further harassment during the period from when Corbin first complained until she stopped working.
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Section 2000e-2(a)(1) does not treat brief nude scenes shown to employees of both sexes as sexual harassment when the exposure is neither severe nor pervasive nor directed at an employee because of sex.

Sims v. Met Council · filed 2019-08-22(a)(1)

Poor taste does not amount to prohibited sexual harassment.
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Section 2000e-2 requires race-based harassment to be sufficiently severe or pervasive to alter the conditions of employment for a hostile work environment claim.

Perkins v. International Paper Company · filed 2019-08-27(a)(1)

Thus, considering the evidence in the light most favorable to Perkins, we agree with the district court that this evidence does not rise to the level of severity and pervasiveness required by Supreme Court and Fourth Circuit precedent to constitute a hostile workplace.
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Section 2000e-2(a)(1) prohibits requiring an employee to work in a racially hostile environment.

Bryant v. McAleenan · filed 2019-08-27(a)(1)

An employer violates 42 U.S.C. § 2000e-2(a)(1) “by requiring an African-American employee to work in a racially hostile environment.” Boyer-Liberto, 786 F.3d at 277; see Meritor Sav. Bank, FSB v. Vinson, 477 U.S. 57, 65-67 (1986).
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Section 2000e-2(a) prohibits the creation or perpetuation of a discriminatory work environment.

OPPER v. FRED BEANS MOTORS OF DOYLESTOWN, INC. · filed 2019-09-06(a)

This provision not only prohibits discrimination with respect to employment decisions that have direct economic consequences, such as termination, demotion, and pay cuts, but also outlaws the creation or perpetuation of a discriminatory work environment.
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Section 2000e-2(a)(1) permits a hostile work environment claim when sexual harassment is severe or pervasive enough to alter the terms and conditions of employment.

MCDOWELL v. SOUTHWEST AIRLINES CO. · filed 2019-09-10(a)(1)

Considering the totality of the circumstances, while Ms. McDowell understandably found the alleged misconduct unwelcome and offensive, it was not pervasive or severe enough to constitute a cognizable claim under Title VII.
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An employer can defeat a Title VII hostile work environment claim by showing that it took reasonable steps to prevent and correct harassment and that the employee unreasonably failed to use those measures.

Joyner v. Woodspring Hotels Property Management LLC · filed 2019-09-11(a)(1)

After review, we conclude Nationwide has established both prongs of the Faragher-Ellerth defense. Thus, even assuming Joyner alleged facts sufficient to sustain her Title VII claim, summary judgment was properly granted.
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Section 2000e-2(a)(1) requires a hostile work environment claimant to allege an objectively hostile environment that the claimant also perceived as hostile.

Milo v. Cybercore Technologies, LLC · filed 2019-09-17(a)(1)

Additionally, to plead that the environment is sufficiently severe or pervasive, a plaintiff must allege an objectively hostile workplace environment as well as that it was subjectively perceived by the plaintiff as hostile.
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An isolated crude remark, without more, does not create a hostile work environment under Title VII.

Borchardt v. Harkins Fashion Square LLC · filed 2019-09-17(a)(1)

This isolated incident does not support Plaintiff’s claim for sexual harassment.
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Section 2000e-2(a)(1) covers race- or sex-based harassment that creates a hostile work environment.

Mills v. City of Shreveport · filed 2019-09-17(a)(1)

When an employee has been subjected to harassment on the basis of sex or race sufficient to create a hostile work environment, such claims are actionable under Title VII.
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A hostile work environment claim under § 2000e-2(a)(1) fails when the alleged harassment is not objectively severe or pervasive.

Johnson v. CC Metals & Alloys, LLC · filed 2019-09-20(a)(1)

For these reasons, the Court finds that Johnson failed to show that the alleged harassment was objectively severe or pervasive, and thus, he cannot establish a hostile work environment claim as a matter of law.
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Section 2000e-2(a) requires a hostile work environment claim to be based on a protected characteristic such as race, national origin, or sex.

Rodriguez v. Danbury · filed 2019-09-30(a)

As with any Title VII claim, plaintiff must prove that the hostility he experienced was “because of” a protected characteristic such as race, national origin, or sex; Title VII is not a “general civility code for the American workplace.”
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Section 2000e-2(a)(1) makes sexual harassment actionable when it is severe or pervasive enough to alter employment conditions and create an abusive work environment.

Davis v. Stephens County Board of County Commissioners · filed 2019-09-30(a)(1)

Evaluating the totality of the circumstances and viewing the record in the light most favorable to Plaintiff, the Court finds Plaintiff cannot establish that the conduct at issue was sufficiently severe or pervasive to support a hostile work environment claim.
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Section 2000e-2(a)(1) prohibits sexual harassment that is severe or pervasive enough to create a hostile work environment.

Covington v. Johnson · filed 2019-10-01(a)(1)

Considering the totality of the circumstances, a reasonable jury could find Covington’s work environment was objectively hostile and adversely affected her ability to train to be a telecommunicator.
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Section 2000e-2(a) prohibits sex-based harassment that is severe or pervasive enough to create a hostile work environment.

Shubat, Chelsea v. Cave Enterprises Operations, LLC · filed 2019-10-04(a)

As set forth above, plaintiffs were also subject to ongoing harassment by defendant’s agent and employee Walitshek because of their sex in violation of 42 U.S.C. § 2000e-2(a), including verbal, physical, and written conduct that were sexual and offensive in nature, all of which was unwelcomed by plaintiffs. Walitshek also used his position of power as plaintiffs’ direct manager to coerce them into tolerating and playing along with this sexually offensive conduct. This conduct was so severe or pervasive that reasonable persons in plaintiffs’ positions would find their work environment to be hostile or abusive.
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An employer may avoid liability for a hostile work environment when an employee fails to use its anti-harassment reporting procedure, denying it an opportunity to correct the conduct.

Schaefer v. Peralta · filed 2019-10-15(a)(1)

This Court is duty-bound to adhere to the Supreme Court’s controlling precedent and must grant the Parish’s motion for summary judgment on Schaefer’s hostile work environment claim because she failed to avail herself of the Parish’s anti-harassment policy to report Peralta’s alleged workplace conduct as would have allowed the Parish an opportunity to correct and prevent the conduct.
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Section 2000e-2(a)(1) prohibits race or national origin harassment that is severe or pervasive enough to create an abusive work environment and alter a term or condition of employment.

Borgonah v. Rocky Mountain Health Center Pediatrics P.C. · filed 2019-10-18(a)(1)

To plead a plausible hostile work environment claim Ms. Borgonah must allege (1) she is a member of a protected class; (2) she was subject to unwelcome harassment, based (3) on her race or national origin; and (4) the harassment was so severe or pervasive that it altered a term, condition, or privilege of her employment and created an abusive work-environment. ... For these reasons, it would be futile to grant Ms. Borgonah leave to amend as to her hostile work environment claim.
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Section 2000e-2(a)(1) prohibits race discrimination, including severe or pervasive racist conduct in the workplace.

Chambers v. York County Prison · filed 2019-10-21(a)(1)

As applied here, a reasonable person, assuming the allegations in the complaint are true, could come to no other conclusion than YCP has been at best complicit in, and at worst actively participating in, a widespread culture of racist activity towards its black employees, and that Plaintiffs have been particularly targeted by this conduct. ... While the court makes no judgment as to whether Plaintiffs’ facts are actually true—Defendants may very well be able to defend themselves at trial—the facts as alleged fall squarely within the type of conduct Title VII and the PHRA have made illegal.
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Section 2000e-2(a)(1) permits a sexual harassment claim to proceed when a reasonable jury could find an objectively hostile work environment.

Sambrano v. Palmetto Heights Management LLC · filed 2019-10-22(a)(1)

Viewing the record in a light most favorable to Plaintiff, the Court finds that a reasonable jury could conclude that Plaintiff was exposed to an objectively hostile work environment while employed at Clarion.
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Section 2000e-2(a)(1) requires harassment to be sufficiently severe or pervasive to alter employment conditions for a hostile work environment claim.

Tigner v. Charlotte-Mecklenburg Schools · filed 2019-10-23(a)(1)

Here, even considering the events that occurred in January and July 2016, Plaintiff fails to allege harassment that was sufficiently severe or pervasive to alter the conditions of her employment and create an abusive working environment.
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Section 2000e-2(a)(1) permits a sexual harassment claim to proceed when a reasonable jury could find that the employee faced an objectively hostile work environment.

Barnett v. Palmetto Heights Management LLC · filed 2019-10-28(a)(1)

Viewing the record in a light most favorable to Plaintiff, the Court finds that a reasonable jury could conclude that Plaintiff was exposed to an objectively hostile work environment while employed at the Airport Inn.
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Section 2000e-2(a)(1) allows a sexual harassment claim to proceed when the evidence could support a finding of an objectively hostile work environment.

Slawson v. Palmetto Heights Management LLC · filed 2019-10-31(a)(1)

Viewing the record in a light most favorable to Plaintiff, the Court finds that a reasonable jury could conclude that Plaintiff was exposed to an objectively hostile work environment while employed at The Airport Inn.
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Section 2000e-2(a)(1) allows a hostile work environment claim to proceed when evidence raises a factual dispute over whether harassment was severe or pervasive enough to affect employment conditions.

Equal Employment Opportunity Commission v. Safie Specialty Foods Company, Inc. · filed 2019-11-05(a)(1)

The Court concludes that the EEOC has presented sufficient evidence to create an issue of fact as to whether the harassment was severe and pervasive enough to constitute a hostile work environment.
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Section 2000e-2(a)(1) allows allegations of harassment based on multiple protected characteristics to be considered together when assessing a hostile work environment claim.

White v. Fidelity Brokerage Services LLC · filed 2019-11-15(a)(1)

Therefore, the Court finds it appropriate to view the allegations collectively in assessing whether plaintiff states a hostile work environment claim.
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Section 2000e-2(a)(1) covers sexual harassment that is severe or pervasive enough to alter employment conditions and create a hostile work environment.

Back v. Commonwealth Of Virginia · filed 2019-11-27(a)(1)

Looking at the record here, no reasonable jury could find that Back’s workplace was objectively hostile.
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Section 2000e-2 prohibits sex discrimination that creates a hostile work environment; an employer’s admission of that violation can establish liability.

Adam v. Airway Manufacturing Co. · filed 2019-12-05

By virtue of its failure to respond, Airway has admitted that it: 1) discriminated against Adam based on sex by creating a hostile work environment, in violation of 42 U.S.C. § 2000e-2; 2) discriminated against Adam on the basis of sex, in violation of O.R.C. § 4112.02(A); and 3) retaliated against Adam for engaging in protected activity, in violation of O.R.C. § 4112.02(I).
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A Title VII hostile work environment claim requires intentional discrimination that is severe or pervasive, affects the employee and a reasonable person in similar circumstances, and supports employer liability.

FERENCIN v. LEHIGH UNIVERSITY · filed 2019-12-27(a)(1)

Regarding the plaintiff’s Title VII claim, to prevail on this claim “the plaintiff must establish that 1) the employee suffered intentional discrimination because of his/her sex [or race], 2) the discrimination was severe or pervasive, 3) the discrimination detrimentally affected the plaintiff, 4) the discrimination would detrimentally affect a reasonable person in like circumstances, and 5) the existence of respondeat superior liability.” Mandel v. M & Q Packaging Corp. 706 F.3d 157, 167 (3d Cir. 2013); see also 3d Cir. Model Jury Instructions § 5.1.4.
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Section 2000e-2(a) requires harassment to be because of the employee’s race to support a racial hostile work environment claim.

Mullens, Chad v. Adams County Government · filed 2020-01-06(a)

In these circumstances, in which there is no evidence that Andy’s animosity towards Mullens had anything to do with Mullens’ association with any minority person, it would be unreasonable to infer that Andy’s alleged harassment was because of Mullens’ racial association, however much Andy’s specific remarks would have racial overtones in a different setting.
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Section 2000e-2(a)(1) covers sex-based hostile work environment claims, but rude, nonsexual conduct did not establish such a claim here.

Newbury v. City of Windcrest, Texas · filed 2020-01-07(a)(1)

Under the undisputed facts presented, Newbury cannot establish a prima facie case of hostile work environment based on sexual harassment. Newbury asserts only that Officer Jaime was rude and offensive based upon nonsexual comments and behavior.
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Section 2000e-2 requires an employer facing a hostile work environment claim based on a coworker’s sexual harassment to have notice of the harassment and to respond with measures reasonably calculated to end it.

Jackson v. Kansas City KS Public Schools · filed 2020-01-07

We thus conclude USD 500 did not have actual or constructive knowledge of the sexual misconduct until December 2016. ... USD 500’s response was thus reasonably calculated to end the harassment.
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Section 2000e-2(a)(1) prohibits sex-based harassment that affects a term, condition, or privilege of employment.

Steak N Shake Inc. v. White · filed 2020-01-07(a)(1)

Assuming without deciding that this incident qualifies as sex-based harassment, the Court finds that it does not satisfy the fourth element of a hostile work environment claim. White has failed to show that this single incident affected a term, condition, or privilege of her employment.
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Section 2000e-2(a)(1) does not support a hostile work environment claim based on a single incident that is not sufficiently extreme.

Reynolds v. Ohio County Fiscal Court · filed 2020-01-08(a)(1)

The isolated incident that Reynolds experienced, while disgusting, is not extreme enough to support a hostile work environment claim.
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A hostile work environment claim requires facts showing severe or pervasive sex-based conduct; conclusory allegations of repeated harassment are insufficient.

Fisher v. J.O. Spice and Cure Company, Inc. · filed 2020-01-22(a)

Here, Fisher falls short of her requirement to show that any alleged conduct falling within the relevant time period was “severe or pervasive.”
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Section 2000e-2(a) covers religious harassment that is severe or pervasive enough to alter an employee’s working conditions.

Schaaf v. New York State Department of Transportation · filed 2020-01-22(a)

Considering the severity, frequency, and degree of the abuse, the Court finds that an objective reasonable person could find that it altered the conditions of his employment for the worse.
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Section 2000e-2(a)(1) requires a hostile work environment claim to allege harassment based on a protected trait; repeated promotion denials alone do not establish such a claim.

Pratt v. Brennan · filed 2020-01-22(a)(1)

Here, Plaintiff has failed to plausibly allege a hostile work environment claim. ... Although Plaintiff alleges that she was repeatedly denied positions for which she was qualified, (Am. Compl. ¶¶ 63, 73), other than a conclusory statement that Plaintiff “experienced a hostile work environment,” no other allegations of incidents of race or gender-based harassment appear in the Amended Complaint, (id. ¶ 63).
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Section 2000e-2(a)(1) covers a hostile work environment when alleged race-based harassment is sufficiently severe or pervasive to alter working conditions.

Bynum v. District of Columbia · filed 2020-01-30(a)(1)

Although the Court acknowledges that Ms. Bynum could have stated her hostile work environment claim more artfully, Ms. Bynum does allege facts from which a reasonable inference can be drawn that the post-assault harassment occurred because of Ms. Bynum’s race. The alleged facts, however, do not support an inference that the alleged hostility is linked to Ms. Bynum’s sex.
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A race-based hostile work environment claim can proceed under § 2000e-2(a)(1) without a separately alleged adverse employment action.

Weatherall v. Mukwonago · filed 2020-01-31(a)(1)

Although Weatherall alleged in her complaint that she is constantly supervised, had to do a lot of work by herself, and that she has been called “a stupid black nigga,” she has not alleged that any adverse employment action was taken against her. However, the court construes her complaint as at least alleging that she was subject to a hostile work environment.
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Section 2000e-2(a) permits a hostile work environment claim based on gender-specific harassment the employee experienced, even when the conduct was not directed at her.

Massey v. Dorning · filed 2020-02-07(a)

For this reason, Massey’s allegation that she was exposed to the conduct that created a hostile work environment is sufficient to state a claim.
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Section 2000e-2(a)(1) requires race-based harassment to be severe or pervasive enough to alter employment conditions for a hostile work environment claim.

Andrews v. Virginia Polytechnic Institute and State University · filed 2020-02-12(a)(1)

The court agrees that Dr. Andrews’ evidence would not allow a reasonable jury to find severe or pervasive harassment.
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Section 2000e-2(a) prohibits sex-based hostile work environments when harassment is severe or pervasive enough to affect employment conditions.

Perez v. Cook County Sheriff's Office · filed 2020-02-18(a)

Under Title VII, an employer violates the statute if an employee is subjected to a hostile work environment based upon the employee’s sex. ... Taken in the light most favorable to Plaintiff, these allegations plausibly create an inference that Plaintiff was subjected to a severe and pervasively hostile work environment based upon her sex. Therefore, this Court denies Defendants’ motion to dismiss Counts I and III.
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Sex-based harassment may violate § 2000e-2 when it is severe enough to create a hostile work environment, even if it occurs on one evening.

Blue v. Hartford · filed 2020-02-19(a)(2)

Rather, the conduct that Plaintiff alleges in the case at bar is consistent with prior hostile work environment case law; and the Court cannot conclude as a matter of law that Plaintiff has not made out a claim of a hostile work environment.
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Section 2000e-2(a)(1) requires an employer that knows of sex-based workplace harassment to take prompt remedial action reasonably calculated to end it.

Doe v. The City of Detroit · filed 2020-02-19(a)(1)

Title VII makes it is unlawful for an employer “to discriminate against any individual with respect to [her] compensation, terms, conditions, or privileges or employment, because of such individual’s . . . sex.” 42 U.S.C. § 2000e–2(a)(1). ... The City took prompt remedial action calculated to end the harassment.
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Section 2000e-2(a)(1) requires a hostile work environment plaintiff to show harassment because of a protected status.

Brown v. Bratton · filed 2020-02-21(a)(1)

To satisfy the second element of a hostile work environment claim, the plaintiff must demonstrate that he was harassed or otherwise discriminated against “because of” his protected class.
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A race-based hostile-work-environment claim requires evidence that the harassment occurred because of the employee’s race.

Patrick v. Walmart Inc · filed 2020-02-24(a)(1)

However, Plaintiff has not presented any evidence that the actions of O’Neal or the alleged use of the “n” word by the other unloaders was directed towards her because of her race.
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Section 2000e-2 requires discriminatory harassment to be severe or pervasive enough to alter the terms and conditions of employment for a hostile work environment claim.

Callahan v. City of Jacksonville, Florida · filed 2020-02-26

Callahan failed to establish that the alleged harassment was severe or pervasive enough to alter the terms and conditions of her employment.
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Section 2000e-2(a)(1) allows a hostile work environment claim to proceed when a jury could find that sex-based harassment was severe or pervasive.

Equal Employment Opportunity Commission v. Magneti Marelli of Tennessee, LLC · filed 2020-02-26(a)(1)

Again, there is material evidence for a jury to find that Degraffenreid’s conduct was severe or pervasive, and summary judgment for Magneti is improper.
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Section 2000e-2(a)(1) prohibits a hostile work environment only when the employee is singled out based on a protected characteristic.

Roderick v. BRC Rubber and Plastics · filed 2020-03-05(a)(1)

This admission dooms his claim because a hostile work environment is unlawful under Title VII only when the plaintiff is singled out based on a protected characteristic.
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Section 2000e-2(a)(1) prohibits sex-based harassment that is sufficiently severe or pervasive to alter the terms or conditions of employment.

Tison v. Alachua Straw Company LLC (MHT) · filed 2020-03-06(a)(1)

Tison has presented ample evidence from which a reasonable jury could find that Wade’s harassment of her was severe and pervasive.
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Section 2000e-2(a) covers racial harassment by a supervisor that is severe or pervasive enough to alter an employee’s working conditions.

Mason v. Sun Recycling, LLC. · filed 2020-03-09(a)

Regarding the third and fourth elements, Evin, a supervisor, routinely used a racist term when addressing Plaintiff during a roughly four-month period of time. During the last incident, Plaintiff showed Evin an EEOC complaint that he intended to file. Roughly two days after this last incident, Plaintiff was fired, i.e., his condition of employment was clearly altered. Plaintiff has met his burden. ... Accordingly, Sun Recycling’s Motion to Dismiss Count I, as it relates to an allegedly hostile work environment created by a Sun Recycling supervisor “Evin” is DENIED.
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A single incident of sexual harassment supports a hostile work environment claim under § 2000e-2(a)(1) only if it is extremely severe.

Diaz v. Richardson · filed 2020-03-12(a)(1)

Thus, the court is left with a single instance of sexual harassment, which must be “extremely severe” to support plaintiff’s claim.
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A single incident cannot establish pervasive harassment for a hostile work environment claim under § 2000e-2(a)(1).

Petty v. Circle K Stores Incorporated · filed 2020-03-13(a)(1)

A claim for “pervasive” harassment must be based on more than a single incident.
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Section 2000e-2(a)(1) requires a hostile work environment claimant to show that the harassment occurred because of a protected characteristic.

U.S. Equal Employment Opportunity Commission v. Ecology Services, Inc. · filed 2020-03-19(a)(1)

To satisfy the second element of a hostile work environment claim, the plaintiff must demonstrate that she was harassed or otherwise discriminated against “because of” her protected class.
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Section 2000e-2(a)(1) requires a hostile work environment claim to plausibly allege harassment because of sex that is severe or pervasive.

Quattrucci v. Massachusetts General Hospital · filed 2020-03-20(a)(1)

Because Quattrucci has not plausibly alleged that he was discriminated against because of his sex or that the purported harassment was severe or pervasive, his hostile work environment claim fails to state a claim upon which relief can be granted.
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An employer can avoid liability for a supervisor-created hostile work environment by showing reasonable care to prevent and correct harassment and an employee’s unreasonable failure to use available remedies, if no tangible employment action occurred.

Calvillo v. Paik · filed 2020-03-30(a)(1)

Thus, plaintiff failed to use any of the measures available to her to inform Centerfolds about the alleged sexual harassment. Defendants effectively raise the affirmative defense and the court grants defendants’ motion for summary judgment as to this claim against Centerfolds.
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Section 2000e-2(a)(1) prohibits sex discrimination in employment, including sexual harassment and a hostile work environment.

Moore v. San Carlos Park Fire Protection & Rescue · filed 2020-04-01(a)(1)

Title VII’s prohibition encompasses various forms of sexual harassment, including a hostile work environment.
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Section 2000e-2(a)(1) covers race-based workplace harassment that is sufficiently severe or pervasive to alter the conditions of employment.

Melvin v. Barr Roofing Company · filed 2020-04-07(a)(1)

We hold that, under the totality of the circumstances, Melvin has alleged that the harassment was sufficiently severe or pervasive.
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Section 2000e-2(a)(1) requires racial harassment to be severe or pervasive enough to alter employment conditions; three isolated statements over several years do not suffice.

Davidson, Vickey v. State Collection Services Inc. · filed 2020-04-08(a)(1)

So Davidson has evidence to support only three of statements by Thurow, which is not enough to support a hostile work environment claim.
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Section 2000e-2(a)(1) prohibits a sex-based hostile work environment when harassment is severe or pervasive enough to alter employment conditions and can be imputed to the employer.

Deprey v. FedEx Freight, Inc. · filed 2020-04-08(a)(1)

Deprey has adduced sufficient evidence to create genuine disputes of material as to whether he was harassed because of his sex, whether the harassment was so severe or pervasive as to alter the conditions of his employment, and whether the harassment can be imputed to FedEx. Therefore, I deny summary judgment on Deprey’s Title VII claim.
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Section 2000e-2(a)(1) covers a hostile work environment when unwelcome sexual conduct is sufficiently severe or pervasive to alter employment conditions.

Kali v. Bulk Handling System · filed 2020-04-10(a)(1)

Here, plaintiff’s complaint lacks sufficient factual allegations to establish a hostile work environment claim or a retaliation claim under Title VII.
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A single sufficiently severe incident of sexual harassment can affect a term or condition of employment under § 2000e-2(a)(1).

Brandon v. Woodspring Suites Shreveport-Bossier City L L C · filed 2020-04-13(a)(1)

The Court finds that Plaintiff has demonstrated that a genuine issue of material fact exists as to whether Gladney’s harassment, although confined to a single incident, was severe enough to affect a term, condition, or privilege of her employment.
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Section 2000e-2(a) allows a race-based hostile work environment claim when the pleaded facts plausibly show severe or pervasive racial harassment and a basis for employer liability.

Ross v. The University of Chicago · filed 2020-04-28(a)

Although it is a close question, the allegations contained within Ross’s second amended complaint and the inferences that reasonably can be drawn from them at the pleading stage plausibly suggest that Ross may be entitled to relief for his hostile work environment claims under Title VII and Section 1981.
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Section 2000e-2(a)(1) requires a hostile work environment claim to be based on race, color, religion, sex, or national origin.

Greenwood v. Frost · filed 2020-04-30(a)(1)

As the Court explained in the September 23 Order, although Title VII prohibits discrimination, it does so only with respect to race, color, religion, sex, or national origin. See September 23 Order at 11 (citing 42 U.S.C. § 2000e-2(a)(1)).
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A complaint alleging race-based workplace harassment may survive initial screening under § 2000e-2(a)(1) despite an inconclusive EEOC investigation.

Woolfolk v. De Paul · filed 2020-05-01(a)(1)

While the EEOC’s determination (or lack thereof) does not hold any substantive weight in a Court’s final analysis, it is nonetheless noteworthy to the Court and helps Woolfolk overcome the low threshold at this early stage. Accordingly, the Court finds Woolfolk’s complaint sufficient to survive initial review.
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Section 2000e-2 requires a hostile work environment claim to show that the harassment was because of the employee’s protected class.

U.S. Equal Employment Opportunity Commission v. Ecology Services, Inc. · filed 2020-05-01(a)(1)

To satisfy the second element of a hostile work environment claim, the plaintiff must demonstrate that she was harassed or otherwise discriminated against “because of” her protected class.
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Section 2000e-2(a)(1) requires a hostile work environment to target the employee because of membership in a protected class.

Sherman v. Fivesky, LLC · filed 2020-05-05(a)(1)

Plaintiff himself must be the target of the hostile work environment and subjected to the hostility because of membership in a protected class.
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Section 2000e-2(a)(1) prohibits employment discrimination based on religion or national origin; offhand comments and isolated incidents generally do not establish a hostile work environment.

Blair v. Soap Lake Natural Spa & Resort LLC · filed 2020-05-07(a)(1)

Though Michaelidis’s alleged comments are troubling, the Court finds each falls within the category of offhand comments or isolated incidents insufficient to create liability under Title VII or Washington law.
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Section 2000e-2(a)(1) prohibits racial harassment that is severe or pervasive enough to alter the conditions of employment.

Bacy v. Chickasaw Nation Industries Inc · filed 2020-05-07(a)(1)

The Court agrees that, while a reasonable factfinder could conclude that Laminack’s comment was offensive, this “offensive utterance” does not demonstrate “physically threatening or humiliating” conduct or the level of severity indicative of a Title VII violation.
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Section 2000e-2(a)(1) requires racial harassment to be severe or pervasive enough to alter a term, condition, or privilege of employment for a hostile work environment claim.

Naambwe v. John Morrell & Co. · filed 2020-05-13(a)(1)

In light of these factors and the high standard that a workplace must be permeated with discriminatory intimidation, ridicule and insult so hostile that it poisoned the work environment, the Genzler incident does not objectively support a claim of harassment so severe or pervasive as to alter a term, condition, or privilege of Plaintiffs’ employment.
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Section 2000e-2(a)(1) requires a hostile work environment plaintiff to plead harassment severe or pervasive enough to alter employment conditions.

Jones v. Sun Pharmaceutical Industries, Inc. · filed 2020-05-14(a)(1)

Here, Jones fails to plead sufficient facts to show the third element of a hostile work environment claim: that the discrimination she faced was “sufficiently severe or pervasive to alter the conditions of [her] employment and create an abusive atmosphere.” Mustafa, 313 F. Supp. 3d at 695.
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Section 2000e-2(a)(1) prohibits sexual harassment that is sufficiently severe or pervasive to create a hostile work environment.

Jackson v. Spring Valley Health Care, LLC · filed 2020-05-15(a)(1)

Although I certainly do not condone Tokunboh’s conduct, Jackson has not presented evidence from which a reasonable jury could find that her sexual comments and brief physical contact were sufficiently severe and pervasive to create a hostile work environment.
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Section 2000e-2(a)(1) does not make a coworker’s single racial slur actionable as a hostile work environment when it does not alter the conditions of employment.

Mack v. Wayne County Community College · filed 2020-05-19(a)(1)

Here, Mack’s coworker’s utterance of the phrase “hoe ass nigga,” with nothing more, did not create a hostile work environment.
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Section 2000e-2 prohibits unwelcome race or national-origin harassment that is severe or pervasive enough to create an abusive work environment.

Ramirez-Castellanos v. Nugget Market, Inc. · filed 2020-05-28(a)(1)

To establish a prima facie hostile work environment under either statute, Plaintiffs must show: (1) they were subjected to verbal or physical conduct because of their race or national origin, (2) the conduct was unwelcome, and (3) the conduct was sufficiently severe or pervasive to alter the conditions of Plaintiffs’ employment and create an abusive work environment.
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Section 2000e-2 prohibits sex discrimination in employment, including sexual harassment that creates a hostile work environment.

Galarza-Cruz v. Grupo HIMA San Pablo, Inc. · filed 2020-05-28

Title VII makes it unlawful for an employer to discharge or otherwise discriminate against any individual with respect to their “compensation, terms, conditions or privileges of employment” because of an individual's sex. 42 U.S.C.A. § 2000e-2. It is well established that sexual harassment, in the form of a hostile work environment, can constitute sex discrimination.
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Section 2000e-2(a)(1) requires sexual harassment to be severe or pervasive enough to alter a term or condition of employment.

Singleton v. City Marshal Office of Monroe · filed 2020-05-29(a)(1)

When considered together, two crude and/or suggestive comments over a two-year period do not rise to the level of an actionable hostile work environment.
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For hostile work environment liability under § 2000e-2(a)(1), a team lead who cannot take tangible employment actions against an employee is not a supervisor.

ASKEW v. WAL-MART STORES INC. · filed 2020-06-01(a)(1)

As Vance requires, a supervisor must be empowered to take a tangible employment action against the victim; at no time in the period during which Mr. Askew allegedly was subject to a hostile work environment did Mr. Yeary have any authority to take a tangible employment action against him—he could not fire, promote, demote, discipline, or transfer him. Under these facts, the court must conclude that Mr. Yeary, although known as the "team lead" at the Tire Center, was not a supervisor within the meaning of Title VII liability.
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A hostile work environment claim based on sex must plausibly allege that the employee’s sex caused the harassment.

Revak v. Miller · filed 2020-06-05(a)(1)

Considering these remarks, as well as Captain Jefferies’s alleged use of a gender epithet, and drawing all reasonable inferences in plaintiff’s favor, plaintiff has plausibly alleged that gender animus fueled Captain Jefferies’s alleged hostility towards her.
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Section 2000e-2(a)(1) permits a hostile work environment claim when national origin harassment is severe or pervasive enough to alter the conditions of employment.

Fernandez v. Trees, Inc. · filed 2020-06-09(a)(1)

Considering the totality of the circumstances, guided by the appropriate factors, we conclude that Fernandez provided evidence sufficient to raise a material issue of fact whether the harassment was objectively severe or pervasive.
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A hostile work environment claim under Section 2000e-2(a)(1) requires harassment sufficiently severe or pervasive to alter the conditions of employment under an objective standard.

Bostic v. City of Jenks · filed 2020-06-09(a)(1)

Plaintiff is a member of a protected group and alleges that she was subject to unwelcome harassment, but she has not alleged that the harassment was sufficiently severe or pervasive to alter the terms and conditions of her employment under an objective standard.
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An employee can state a hostile work environment claim against her employer for sexual harassment by a non-employee when she alleges that the employer knew of the harassment and failed to take corrective action.

Albright v. American Greetings Corporation · filed 2020-06-18(a)(1)

These allegations, viewed in Albright’s favor, are sufficient to state a claim for hostile work environment against AGC.
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Section 2000e-2(a)(1) requires race-based harassment to be sufficiently severe or pervasive to create an objectively hostile work environment.

Bozeman v. Arkansas Foundation for Medical Care · filed 2020-06-29(a)(1)

But, given the precedent in this Circuit, no rational jury could find that AFMC’s conduct rises to the level of severity and pervasiveness that would be actionable under Title VII.
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Section 2000e-2(a)(1) permits a hostile work environment claim to proceed when repeated unwelcome touching and an employer’s inadequate response plausibly establish sex-based harassment.

La Giglio v. AssuredPartners of Illinois, LLC · filed 2020-07-02(a)(1)

La Giglio has properly alleged the elements of a claim for hostile work environment sexual harassment. Because she has raised more than a speculative possibility of a right to relief, La Giglio has stated a claim on which relief can be granted as to Count I. Accordingly, the motion to dismiss the claim of hostile work environment sexual harassment is denied.
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Section 2000e-2(a)(1) requires a hostile work environment claim to allege conduct that is severe or pervasive; repeated requests for dates, without more detail, are insufficient.

Coates v. Suthars, Inc. · filed 2020-07-08(a)(1)

Examining Plaintiff’s allegations as pled, she has failed to allege conduct that was “severe or pervasive.”
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Section 2000e-2(a)(1) permits a sex-based hostile work environment claim when unwelcome harassment is sufficiently severe or pervasive and the employer can be held responsible for it.

Coffey v. Tyler Staffing Services, Inc. · filed 2020-07-09(a)(1)

Accordingly, at least at the motion to dismiss stage, the court finds sufficient facts alleged to impute liability to Servicemaster and sustain Coffey’s hostile work environment claim.
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An employer with notice of sexual harassment may fail its duty to take prompt remedial action by pressuring the employee to work near her harasser.

Batayias v. The Mechanical Shop, Inc. · filed 2020-07-14(a)(1)

In terms of promptly remedying sexual harassment, pressuring an employee until she agrees to work near her harasser is just as ineffective as directly ordering an employee to return to the location of harassment.
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Section 2000e-2(a) prohibits discrimination based on gender stereotyping and covers a hostile work environment when the alleged conduct is sufficiently severe or pervasive.

JANE DOE v. DUNKIN' DONUTS · filed 2020-07-16(a)

It naturally follows that discrimination based on gender stereotyping falls within Title VII’s prohibitions.
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Section 2000e-2(a)(1) covers sex-based harassment when it is severe or pervasive enough to alter the conditions of employment.

JONES v. THE MON VALLEY INITIATIVE · filed 2020-07-20(a)(1)

However, this court cannot conclude that the sex-related comments or the touching-related incidents rise to the level required to be so “severe or pervasive” as to establish a hostile work environment.
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Section 2000e-2(a)(1) permits a hostile work environment claim based on sexual harassment, but the complaint must allege facts describing the harassment.

Dyson v. Board of Supervisors of Southern University and A&M College · filed 2020-07-23(a)(1)

Plaintiff does not allege any detailed facts constituting sexual harassment or retaliation as defined by law.
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Section 2000e-2(a)(1) requires sex-based harassment to be severe or pervasive enough to create a hostile work environment.

Gabeau v. Starnes · filed 2020-08-03(a)(1)

As previously noted, Starnes’ comments cannot be considered severe or pervasive as a matter of law.
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Section 2000e-2(a) requires a hostile work environment claim to allege harassment based on membership in a protected class.

Miller v. Aerotek Scientific · filed 2020-08-05(a)

Because Plaintiff fails to show that the alleged harassment he suffered stems from his membership in a protected class, he fails to state a claim upon which relief may be granted.
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Section 2000e-2(a) allows a hostile work environment claim to reach a jury when the evidence could support a finding that the harassment was severe or pervasive.

Kennedy v. Berkel & Company Contractors, Inc. · filed 2020-08-20(a)

A reasonable jury could find that these acts taken together were “severe or pervasive” enough to create a hostile work environment.
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An employer may be liable for a hostile work environment when supervisors knew or should have known of sexual harassment and failed to remedy it promptly.

Cross v. Alabama, State Department of Mental Health & Mental Retardation · filed 1995-04-06(a)(1)

As to Horsley and Poundstone, the law requires appellees to establish that Horsley and Poundstone knew or should have known of the harassment and failed to take prompt action to remedy the violation. ... Here, also, appellees presented sufficient evidence for the-finding that Horsley and Poundstone knew or should have known of Stricklin’s discriminatory treatment of female employees, yet failed to take prompt action to remedy the hostile work environment Stricklin’s conduct created.
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Section 2000e-2(a)(1) covers hostile work environment claims based on national origin.

Gharzouzi v. Northwestern Human Services of Pennsylvania · filed 2002-05-06(a)(1)

First recognized by the Supreme Court in ... a case in which the plaintiff claimed sexual harassment, the hostile work environment doctrine “is now established as a basis for various discrimination claims,” ... including claims based on national origin.
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Section 2000e-2(a)(1) covers sex-based harassment that is objectively offensive enough to alter employment conditions and create an abusive working environment.

Moore v. U.S. Virgin Islands Department of Tourism · filed 2020-08-31(a)(1)

Only those that are so objectively offensive that they “alter the conditions of [the plaintiff’s] employment and create an abusive working environment” are actionable.
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Gender-based harassment supports a hostile work environment claim under § 2000e-2(a)(1) when it is severe or pervasive enough to alter employment conditions.

McNiel v. Atlantic Properties Management Corp. · filed 2020-09-02(a)(1)

But analyzing all of the undisputed material facts, the Court finds that the evidence of Defendants’ actions are not enough to establish that Ms. Ricci and Ms. Galvin faced an environment of severe and pervasive hostility based on their gender and Ms. Ricci’s age.
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Section 2000e-2(a)(1) requires a hostile work environment to alter the conditions of employment; an accusation made after termination cannot do so.

MCILVAINE v. 1SEO TECHNOLOGIES, INC. · filed 2020-09-10(a)(1)

Plaintiff cannot show that Defendants altered the conditions of his employment to create a hostile work environment when he already had been fired, and therefore summary judgment will be granted as to claim.
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Section 2000e-2(a)(1) requires a hostile work environment to alter the terms and conditions of employment.

Milord-Francois v. The New York State Office of the Medicaid Inspector General · filed 2020-09-23(a)(1)

The hostile work environments prohibited by Title VII are those that alter the “terms and conditions” of employment.
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Section 2000e-2(a)(1) requires courts to consider alleged racial harassment in its workplace context; apparently neutral incidents may also be based on race.

Okoli v. Michelin North America Inc-BF Goodrich · filed 2020-09-24(a)(1)

Considering the explicit racist character of several incidents, a reasonable jury could conclude that the superficially neutral incidents were also based on race.
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Section 2000e-2(a)(1) requires sexual harassment to be severe or pervasive enough to alter employment conditions for a hostile work environment claim.

VINCENT v. NORTH CAROLINA DEPARTMENT OF TRANSPORTATION · filed 2020-09-24(a)(1)

The facts alleged do not support a reasonable inference that the conduct was so severe or pervasive so as to alter the conditions of Plaintiff’s employment and to create an abusive work environment.
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Section 2000e-2(a)(1) requires a hostile work environment plaintiff to show unwelcome harassment because of race or gender that affected a term, condition, or privilege of employment.

Watson v. Century Management LLC · filed 2020-09-25(a)(1)

Under both federal and state law, to establish a claim for hostile work environment based on race or gender a plaintiff must show that: (1) he or she is a member of a protected group; (2) he or she was subjected to unwelcome race-based or gender-based harassment; (3) the harassment was because of membership in the protected group; and (4) the harassment affected a term, condition, or privilege of his or her employment.
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Section 2000e-2(a) allows a race-based hostile work environment claim against an employer when a supervisor’s severe or pervasive harassment alters an employee’s working conditions.

Gates v. Eutectic Castolin · filed 2020-09-29(a)

The plaintiff has stated that he was subject to unwelcome harassment from Daniels, that it was based on the plaintiff’s race and that it was so severe and pervasive that it resulted in a hostile work environment. ... The court will allow the plaintiff to proceed against Eutectic Castolin under Title VII and against Daniels under 42 U.S.C. §1981.
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Section 2000e-2(a)(1) prohibits a hostile work environment based on a protected trait; the plaintiff must show objectively hostile or abusive conditions.

Johnson v. Secretary of Veterans Affairs · filed 2020-09-29(a)(1)

As to the second element of a hostile work environment claim, Plaintiff has not demonstrated that her work environment was objectively hostile or abusive under Title VII.
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Section 2000e-2(a)(1) permits a jury to consider facially neutral acts as part of sex-based harassment when their context supports that inference.

Sanderson v. Wyoming Highway Patrol · filed 2020-09-30(a)(1)

When considered alongside the facially sex-based incidents, a jury could find that other hostile acts, which were not explicitly sexual in nature, were nevertheless part of the sexual harassment against Sanderson and contributed to a sexually hostile work environment.
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A hostile work environment claim under § 2000e-2(a)(1) requires discriminatory conduct sufficiently severe or pervasive to change the conditions of employment.

Scutt v. Carbonaro CPAS N MNGMT GRP · filed 2020-10-02(a)(1)

In particular, Plaintiff’s Complaint fails to allege discriminatory conduct that is sufficiently severe or pervasive to have changed the terms and conditions of her employment.
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Section 2000e-2(a)(1) requires race-based harassment to be sufficiently severe or pervasive to create a hostile work environment.

Davis v. The Boeing Company · filed 2020-10-06(a)(1)

The conduct described by Plaintiff falls far short of rising to a level of harassment that the Court would characterize as sufficiently severe or pervasive as to constitute a hostile work environment as a matter of law under Title VII.
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A hostile work environment claim based on sex or national origin may proceed when factual disputes remain about whether the alleged conduct was discriminatory.

Ceballos-Germosen v. Sociedad Para Asistencia Legal · filed 2020-10-07(a)(1)

This court understands such appreciation to be simplistic and incorrect because, as we will see, the record does not reflect with certainty a total lack of relationship between Ceballos’ sex or national origin and Defendants’ conduct. Consequently, the uncontested evidence on file is not enough to warrant dismissal.
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A racial hostile work environment claim requires harassment severe or pervasive enough to alter the terms or conditions of employment.

Bone v. Alliance Investment Company LLC · filed 2020-10-08(a)(1)

Defendant contends in its motion that Plaintiffs failed to present substantial evidence that the harassing conduct was sufficiently severe or pervasive to alter the terms or conditions of his employment. The Court agrees.
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Section 2000e-2 permits a racial hostile work environment claim when race-based harassment is severe or pervasive enough to alter the conditions of employment.

Williams v. Aeroflex Wichita, Inc. · filed 2020-10-15(a)(1)

The Court concludes that the record contains insufficient evidence that Aeroflex’s workplace was permeated with racial animus “severe or pervasive” enough to “alter the conditions of [Williams’] employment and create an abusive working environment.”
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Section 2000e-2(a) covers a sex-based hostile work environment when the conduct is objectively abusive and the employee subjectively experiences it as abusive.

Blades v. J & S Professional Pharmacy, Inc. · filed 2020-10-22(a)

As for the objective requirement, the Court agrees that a reasonable person in Blades’s position would find the work environment to be objectively abusive.
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Section 2000e-2(a)(1) requires sex-based harassment to be sufficiently severe or pervasive to alter employment conditions for a hostile work environment claim.

Zolfo v. Westminster Village Incorporated · filed 2020-10-27(a)(1)

But this one regrettable incident, coupled with the offensive but offhand remarks made by Plaintiff’s supervisors, did not so pervasively alter the conditions of her employment. The Title VII hostile work environment claim fails.
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A Title VII sexual harassment claim can survive summary judgment when the record leaves genuine factual disputes.

SILLA v. ONE THREE FIVE, INC. · filed 2020-10-27(a)(1)

As Silla has created genuine issues of material fact that Defendants failed to rebut or address, summary judgment in favor of Blush is not warranted regarding Silla’s Title VII claims.
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Section 2000e-2(a)(1) covers a sexually hostile work environment when allegations of a harasser’s continued presence and management threats plausibly show sex discrimination.

Long v. Diamond Dolls of Nevada, LLC · filed 2020-10-29(a)(1)

And based on Smith’s alleged conduct in June 2018, March 2019, and discharge threats by management, it is plausible for a jury to find that the Spice House created a sexually hostile working environment.
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An employer cannot establish the affirmative defense to a Title VII hostile work environment claim at summary judgment without evidence that its harassment policy meets the minimum requirements.

Yehia v. Michigan Department of Corrections · filed 2020-11-02(a)(1)

Defendants have not shown that the MDOC’s harassment policy contains those provisions. As such, the MDOC has not established that, at the summary judgment phase of this case, that it is entitled to this affirmative defense.
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A sexual harassment claim can proceed when the evidence raises a genuine factual dispute over whether the plaintiff faced a hostile work environment.

Johnson v. Becerra · filed 2020-11-06(a)(1)

I am convinced that there is sufficient evidence to raise a genuine factual dispute as to whether she experienced a hostile work environment.
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Section 2000e-2(a)(1) requires a hostile work environment claim to allege harassment sufficiently severe or pervasive to alter the conditions of employment.

Mensah v. Mnuchin · filed 2020-11-13(a)(1)

Plaintiff’s allegations are either conclusory or fall far short of alleging a hostile work environment.
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Sexual comments or gestures spread over months do not establish a Title VII hostile work environment when they are too infrequent to be pervasive.

Gove v. Sargento Foods Inc · filed 2020-11-25(a)

The plaintiff’s allegations about Clauson’s behavior do not state a claim for discrimination or for a hostile work environment. The plaintiff says that Clauson told him she was hot in front of a group of women, filed an HR complaint against him with unknown contents, threatened to vandalize his car and twice made sexually suggestive gestures toward him. Three events which the plaintiff construes as having been sexual in nature do not constitute the kind of severe, pervasive harassment described by the Seventh Circuit.
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Section 2000e-2(a)(1) requires pregnancy-related harassment to be sufficiently severe or pervasive to create an abusive work environment.

Coates v. Washoe County School District · filed 2020-12-04(a)(1)

First, the Court finds that none of these allegations are verbal or physical conduct of a pregnancy-related nature. Second, while it is clear from plaintiff’s Complaint that she viewed the conduct as unwelcome, it is neither sufficiently severe nor pervasive such that it created an abusive work environment.
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Section 2000e-2 permits a hostile work environment claim when sex-based conduct is sufficiently severe or pervasive to make the workplace abusive; the court considers the conduct as a whole.

Coates v. Suthars, Inc. · filed 2020-12-14(a)(1)

But, when considered collectively, Suthar’s comments and conduct, including making remarks about watching her during sales calls and liking her too much; constantly asking her out to dinner; inviting her to accompany him on a private plane with a stopover in Richmond if he was feeling “saucy”; sending a sexually suggestive text message at 1:30 in the morning regarding him not wearing pants; berating and humiliating her in front of her direct supervisor out of romantic jealously; and propositioning her to marry him, have his children, and “build an empire” during a work dinner, lead to the valid conclusion that a reasonable person in Coates’s shoes would perceive that working environment to be abusive and hostile.
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Section 2000e-2(a)(1) covers a sex-based hostile work environment when harassment is severe or pervasive enough to affect the conditions of employment.

Saxton v. Mayorkas · filed 2020-12-22(a)(1)

Given all this, a reasonable jury could find that Smith’s conduct was severe or pervasive.
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Notes 6751–6900 of 12,593, oldest cases first.

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