42 U.S.C. § 2000e-2
Unlawful employment practices: the cases that interpreted this section
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
Section 2000e-2(a)(1) requires sexual harassment to be sufficiently severe or pervasive to create an actionable hostile work environment.
Copeland v. District of Columbia · filed 2020-12-23(a)(1)
Unfortunately for Copeland, the alleged incidents of harassment, either standing alone or in the aggregate, are insufficiently severe, or pervasive, to create an actionable hostile work environment under Title VII.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires sex-based harassment to be severe or pervasive enough to create a hostile work environment.
Peck v. Tucson, City of · filed 2021-01-04(a)(1)
Plaintiff established only one action by Defendant based on a gender stereotype. That singular remark was not severe or pervasive and was insufficient to establish a hostile work environment in violation of Title VII.Read the full opinion on CourtListener →
Section 2000e-2 requires harassment to be severe or pervasive enough to alter employment conditions for a hostile work environment claim.
Maiurano v. Cantor Fitzgerald Securities Corp. · filed 2021-01-08
Thus, the Court agrees with Defendant that even if Plaintiff’s allegations were accepted as true, they do not describe an actionably hostile work environment.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires sex-based harassment to be severe or pervasive enough to alter working conditions; merely looking at a colleague does not qualify without evidence of threatening, humiliating, or work-interfering conduct.
Hernandez v. Wilkinson · filed 2021-01-27(a)(1)
However, simply looking at a colleague, without evidence that those looks were, inter alia, severe, an unreasonable interference with work, or physically threatening or humiliating does not constitute harassment.Read the full opinion on CourtListener →
A Title VII hostile work environment claim requires facts supporting a reasonable inference that the plaintiff was harassed because of race or sex.
Brown v. City Of Cincinnati · filed 2021-02-01(a)
Even crediting Plaintiffs’ allegation that Pettis requested that Ludgatis and Brown be transferred, the Amended Complaint still lacks sufficient factual allegations to reasonably infer that Plaintiffs were subjected to harassment based on their race or sex.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) permits a hostile work environment claim based on pervasive sex-based harassment.
MAHR v. PROJECT MANAGEMENT INSTITUTE, INC. · filed 2021-02-01(a)(1)
Considering the totality of Mahr’s allegations in the light most favorable to her, she has stated plausible claims for hostile work environment.Read the full opinion on CourtListener →
Section 2000e-2 requires a hostile work environment claim to allege facts connecting the harassment to a protected trait such as race.
Gaines v. Sheriff of Cook County Thomas J. Dart · filed 2021-02-04
To plead a hostile work environment under Title VII, Plaintiff must allege, among other things, that the harassment was based on membership in a protected class or in retaliation for protected Title VII behavior. ... The Complaint makes no factual allegation whatsoever showing that Plaintiff was harassed because of his race.Read the full opinion on CourtListener →
A hostile work environment claim requires plausible allegations that the harassment occurred because of the employee’s sex.
Henige v. Board of Regents of the University of Wisconsin System · filed 2021-02-11(a)(1)
Although Henige claims that the allegations were false, there are no facts to plausibly suggest that the allegations were made because Henige is male.Read the full opinion on CourtListener →
A sex-based hostile work environment claim under § 2000e-2(a)(1) fails when the employee cannot establish a basis for employer liability.
WILSON v. REGAL BELOIT AMERICA, INC · filed 2021-02-22(a)(1)
Because Wilson cannot satisfy each of the requirements for a Title VII hostile work environment claim, Regal's Motion for Summary Judgment is granted as to this claim.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) bars sex-based harassment that is severe or pervasive enough to create an abusive working environment.
Porter v. 1st Choice After School Kare · filed 2021-03-03(a)(1)
In establishing a hostile work environment claim, Plaintiff shows (1) she is female; (2) she was subjected to verbal and physical harassment; (3) that this harassment was based upon her sex; and (4) that this constant harassment caused Plaintiff to feel unsafe, unwelcome, and to be in constant fear of losing her job or physical harm.Read the full opinion on CourtListener →
For hostile work environment claims, an alleged harasser is a supervisor only if the employer empowered that person to take tangible employment actions against the employee.
Burns v. Berry Global, Inc. · filed 2021-03-09(a)(1)
The record establishes that Bell was not Burns’ supervisor under Title VII. “[A]n employee is a ‘supervisor’ for purposes of vicarious liability under Title VII if he or she is empowered by the employer to take tangible employment actions against the victim.”Read the full opinion on CourtListener →
Section 2000e-2(a) covers workplace harassment only when it is based on sex or another protected characteristic.
Cooper v. Edgewood Management Corporation · filed 2021-03-10(a)
Title VII provides protection only against conduct occurring on the basis of an individual’s membership in a protected class: race, color, religion, sex and national origin. 42 U.S.C. § 2000e-2(a). Because Plaintiff does not allege that the claimed harassment, intimidation, and hostile work environment was tied to his sex or membership in a protected class, the claims will be dismissed.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) covers sex-based harassment that creates a hostile work environment by altering the conditions of employment.
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION v. MEDIACOM COMMUNICATIONS CORPORATION, A NEW YORK CORPORATION · filed 2021-03-16(a)(1)
Viewing the evidence presented in the light most favorable to Plaintiffs, the Court finds that there is sufficient evidence from which a reasonable jury could determine that Christian’s conduct created a hostile working environment and “exposed [Plaintiffs] to disadvantageous terms or conditions of employment to which members of the other sex [were] not exposed.”Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits national-origin harassment that is severe or pervasive enough to alter employment conditions and create an abusive workplace.
Bumbales v. City of Vandalia, Missouri · filed 2021-03-18(a)(1)
"Hostile work environment occurs ‘[w]hen the workplace is permeated with discriminatory intimidation, ridicule, and insult that is sufficiently severe or pervasive to alter the conditions of the victim’s employment and create an abusive working environment.’" Jackman v. Fifth Judicial Dist. Dep’t of Corr. Servs., 728 F.3d 800, 805 (8th Cir. 2013) (quoting Harris v. Forklift Sys., Inc., 510 U.S. 17, 21 (1993)).Read the full opinion on CourtListener →
Section 2000e-2(a)(1) permits a sex-based hostile work environment claim when the conduct alters the conditions of employment and can be imputed to the employer.
Espinosa v. Weill Cornell Medical College · filed 2021-03-19(a)(1)
Espinosa, therefore, has raised a material issue of fact as to her hostile work environment claim under Title VII and the NYSHRL.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a hostile work environment to involve severe or pervasive discrimination; a single incident must be extraordinarily severe.
Kaplan v. New York State Department of Labor · filed 2021-03-22(a)(1)
While a single incident can suffice to substantiate a claim of hostile work environment, such an incident would have to be “extraordinarily severe.” ... The evidence of actionable conduct by Pichardo against Plaintiff was also far less than alleged in the Complaint.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a connection between alleged harassment and an employee's sex for the conduct to support a hostile work environment claim.
SCOTT v. MARION COMMUNITY SCHOOLS · filed 2021-03-30(a)(1)
Because Ms. Scott's designated evidence on these incidents similarly does not support a reasonable inference that this conduct was connected to her sex, they are not relevant for her hostile work environment claim.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a coworker sexual harassment claim to show that the harassment altered a term, condition, or privilege of employment and created an abusive working environment.
Bedenfield v. United Parcel Service, Inc. · filed 2021-03-31(a)(1)
It appears then that the plaintiff’s discrimination claim is actually the same as her hostile work environment claim based on coworkers’ sexual harassment which requires her to prove that “’the harassment altered a term, condition, or privilege of the plaintiff’s employment and created an abusive working environment.” Lounds v. Lincare, Inc., 812 F.3d at 1222 (quoting Harsco Corp. v. Renner, 475 F.3d 1179, 1186 (10th Cir. 2007)).Read the full opinion on CourtListener →
Section 2000e-2 requires workplace harassment to be severe or pervasive enough to alter the conditions of employment and create a hostile work environment.
Vidrine v. Broom · filed 2021-03-31
In sum, because Plaintiffs’ complained of conduct was not severe or pervasive, was relatively infrequent, was not physically threatening, or humiliating, and did not unreasonably interfere with Plaintiffs’ work performance, Plaintiffs have not demonstrated that EMS was a hostile environment.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) covers a hostile work environment when sex-based harassment is sufficiently severe or pervasive to alter employment conditions.
Ruiz v. Bayshore - Brightwaters Rescue Ambulance, Inc. · filed 2021-03-31(a)(1)
In aggregate, the events in the record were sufficiently regular, in light of their relatively humiliating and intimidating nature, that a jury could find that the workplace was hostile.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires severe or pervasive conduct for a hostile work environment claim; one alleged racial slur and an early dismissal did not suffice.
TIllman-Branch v. The Grand Rehab and Nursing at Barnwell · filed 2021-03-31(a)(1)
Drawing all reasonable inferences in Plaintiff's favor, the Court finds that Plaintiff cannot establish that she was subjected to severe or pervasive conduct.Read the full opinion on CourtListener →
Race-based harassment can violate Section 2000e-2(a)(1) when it is severe or pervasive enough to create a hostile work environment.
Chambers v. York County Prison · filed 2021-03-31(a)(1)
Thus, the record creates a genuine issue of material fact as to whether Plaintiffs’ treatment was sufficiently severe and pervasive for a Title VII claim.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires religious or national-origin harassment to be sufficiently severe or pervasive to alter employment conditions for a hostile work environment claim.
Palomino-Alonso v. StoneMor Puerto Rico LLC · filed 2021-04-29(a)(1)
The above instances, considered separately as well as together, do not rise to the level of severe and pervasive harassment for Plaintiff to meet the prima facie elements of her hostile work environment claim on the basis of her religious beliefs.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires alleged sexual harassment to materially alter employment conditions to support a hostile work environment claim.
Gunter v. Shapley & Stern, Inc. · filed 2021-04-30(a)(1)
Where Gunter has not demonstrated any way in which Patterson’s alleged conduct impacted her job, the court concludes that no reasonable fact finder could find that his behavior “materially altered” Gunter’s work conditions within the meaning of Title VII or chapter 151B.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) covers sex-based harassment that creates a work environment the employee and a reasonable person would perceive as hostile.
Dahl v. Tarahumara Express Incorporated · filed 2021-05-07(a)(1)
Plaintiff’s Complaint shows she perceived a hostile work environment, and it shows a reasonable person would agree. The allegations also allow the Court to reasonably draw the inference that the harassment occurred because of Plaintiff’s sex.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a gender-based hostile work environment to be objectively severe or pervasive.
Williford v. Interstate Truckers LTD Assistance Administration · filed 2021-05-12(a)(1)
Rather, accepting as true all of Plaintiff’s allegations as supported by the evidence, the environment was not sufficiently severe or pervasive so as to constitute a hostile work environment.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a race-based hostile work environment claim to allege harassment connected to race that is severe or pervasive enough to alter working conditions.
Scurlock v. Missouri Housing Development Commission · filed 2021-05-14(a)(1)
For all of the above reasons, even when the Court accepts as true all of the factual allegations in the complaint and views the complaint liberally, the Court finds that Plaintiff has not alleged sufficient facts to suggest that Plaintiff has a plausible claim of a hostile work environment based on race.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) permits a national-origin hostile work environment claim based on a prolonged pattern of ethnic slurs and demands that an employee return to his country.
Bernardi v. New York State Department of Corrections and Community Supervision / Bedford Hills Correctional Facility · filed 2021-05-19(a)(1)
Where there is a prolonged pattern of slurs and demands that a plaintiff return to his or her country, courts have found that these comments are “much more than isolated incidents of racial enmity,” and suffice to establish a hostile work environment claim. ... Thus, Defendants’ Motion is denied with respect to Plaintiff’s hostile work environment claims.Read the full opinion on CourtListener →
Section 2000e-2 requires a hostile work environment plaintiff to show that the alleged harassment was severe or pervasive and based on sex.
Roesinger v. Pohanka of Salisbury, Inc. · filed 2021-05-20(a)(1)
Moreover, to establish a prima facie case for hostile work environment, the Plaintiff must show not only that the conduct was severe and pervasive, but also that the employer’s conduct towards her was due to her sex. ... Essentially, Roesinger has simply not shown that any mistreatment by her coworkers was based on her sex.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a Title VII hostile work environment claim to allege harassment because of a protected characteristic.
Carter v. GardaWorld Securities Services - US · filed 2021-05-20(a)(1)
In Count VI of the Complaint, Carter does not allege that his hostile work environment was connected to any protected characteristic.Read the full opinion on CourtListener →
Section 2000e-2(a) requires harassment to be sufficiently severe or pervasive to support a sex-based hostile work environment claim.
Sowash v. Marshalls of MA, Inc. · filed 2021-05-25(a)
Accordingly, the court concludes that Sowash’s evidence of Hughes’s non-sexual touching, welcome-back kiss on the cheek, and compliments do not constitute severe or pervasive workplace conduct sufficient to support a Title VII hostile work environment claim.Read the full opinion on CourtListener →
Sex-based harassment can support a hostile work environment claim under § 2000e-2(a)(1) when it is severe or pervasive.
O'BRIEN v. THE MIDDLE EAST FORUM · filed 2021-05-28(a)(1)
Plaintiff’s Title VII claim must likewise survive because Plaintiff has offered evidence suggesting a genuine dispute concerning severe and pervasive discrimination, as well as respondeat superior liability.Read the full opinion on CourtListener →
Section 2000e-2(a) requires a hostile work environment plaintiff to show severe or pervasive discriminatory conduct that affects the terms and conditions of employment.
RAUCEO v. PHILADELPHIA GAS WORKS · filed 2021-06-10(a)
Accepting and considering in the light most favorable to him all evidence Rauceo believes could support his claim, no reasonable juror could find Rauceo was subjected to severe or pervasive discriminatory conduct because nothing he alleges had any discernable impact on his employment.Read the full opinion on CourtListener →
Section 2000e-2 permits employer liability for third-party harassment when the employer knows of it and fails to take reasonable remedial action.
PETERKIN v. PROSPECT AIRPORT SERVICES, INC. · filed 2021-06-11(a)
An employer may be liable under Title VII for the conduct of third parties if the employer knew about the conduct and failed to take reasonable remedial action in response.Read the full opinion on CourtListener →
Section 2000e-2(a) permits a harassment claim based on race, color, or sex to proceed when the allegations plausibly describe a hostile work environment.
Brown v. Johnsonville Sausage LLC · filed 2021-06-14(a)
Taken together, Brown’s allegations are sufficient to state a claim for harassment as to his race, color, and/or sex. See 42 U.S.C. §2000e-2(a).Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a hostile work environment claim to allege severe or pervasive harassment motivated by race.
Stovall v. H&S Bakery · filed 2021-06-23(a)(1)
In the absence of allegations sufficient to establish severe or pervasive harassment motivated by race, the Court will grant the Motion to Dismiss as to the hostile work environment claim.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a hostile work environment claimant to show that she perceived the workplace as hostile or abusive; rumors she was unaware of cannot satisfy that requirement.
Dawson v. Kroger Limited Partnership I · filed 2021-06-24(a)(1)
On this record, no reasonable jury could find that the rumors altered the conditions of Dawson’s employment or created a subjectively hostile or abusive work environment. Accordingly, the hostile work environment claim cannot survive summary judgment.Read the full opinion on CourtListener →
Section 2000e-2(a) allows a racially hostile work environment claim to proceed when a jury could find a supervisor's racist remarks severe enough to alter working conditions and a basis for employer liability.
Winston v. Dart · filed 2021-06-24(a)
In sum, Winston and Strickland have identified specific, admissible evidence that would support a jury finding on their favor with respect to all four elements of their Title VII claims as well as their section 1983 claims against Ranzino and Shields. The Court therefore denies the defendants' motion for summary judgment with respect to these claims.Read the full opinion on CourtListener →
Section 2000e-2 permits a sex discrimination claim based on a hostile work environment when sexual harassment is sufficiently severe or pervasive to alter employment conditions.
Corradino v. Liquidnet Holdings, Inc. · filed 2021-07-08
These allegations are sufficient to plead that Liquidnet was permeated with pervasive discriminatory intimidation, ridicule and insult.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a hostile work environment claim to allege discrimination because of race, color, religion, sex, or national origin.
Chang v. Department of Homeland Security · filed 2021-07-15(a)(1)
Moreover, Plaintiff must allege that she was discriminated against “because of [Plaintiff’s] race, color, religion, sex, or national origin.” 42 U.S.C. § 2000e–2(a)(1). Here, Plaintiff fails to allege that any bullying or discrimination she experienced in the workplace was due to Plaintiff’s “race, color, religion, sex, or national origin.” As such, Plaintiff has failed to state a claim for a hostile work environment under Title VII.Read the full opinion on CourtListener →
A hostile work environment claim requires specific conduct showing harassment severe or pervasive enough to change the conditions of employment.
Gharadaghian-Riccio v. DMB Sports Clubs LP · filed 2021-08-02(a)(1)
In her briefing, Plaintiff does not articulate any specific actions that constituted pervasive harassment that changed the conditions of her employment. She thus fails to allege a prima facie case of harassment based on hostile work environment.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a plaintiff claiming a racially hostile work environment to show that the harassment was based on race.
Brown v. Bratton · filed 2021-08-10(a)(1)
Plaintiff must next demonstrate that the harassment was based on his race.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits sex-based hostile work environments, and the plaintiff must prove a violation by a preponderance of the evidence.
U.S. Equal Employment Opportunity Commission v. Ecology Services, Inc. · filed 2021-08-11(a)(1)
The Plaintiff has failed to show by a preponderance of the evidence that any illegal or inappropriate touching ever occurred between Hamilton.and Paz.Read the full opinion on CourtListener →
A sex-based hostile work environment claim requires evidence that the employee’s gender caused the alleged harassment.
Revak v. Miller · filed 2021-08-16(a)(1)
Plaintiff fails to produce evidence from which a reasonable trier of fact could find that her gender was the but-for cause of the alleged harassment.Read the full opinion on CourtListener →
Section 2000e-2(a) requires evidence of unwelcome race-based harassment to support a hostile work environment claim.
Winston v. Dart · filed 2021-08-17(a)
None of the other plaintiffs, however, have introduced any evidence that they experienced inappropriate remarks that could be construed as unwelcome race-based harassment by a reasonable factfinder, and thus they cannot establish the first two elements of their hostile work environment claims.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) permits a religious hostile work environment claim when severe or pervasive harassment plausibly alters employment conditions.
Williams v. Newport News School Board · filed 2021-08-19(a)(1)
Nonetheless, at this stage of the proceedings, assuming all Plaintiff’s facts are true and giving her the benefit of all reasonable inferences as required, the Court FINDS that Plaintiff has asserted a plausible claim for hostile work environment.Read the full opinion on CourtListener →
An employer’s investigation, oral reprimand, and required training can constitute prompt remedial action in a hostile work environment claim.
Argueta v. TAG Electric Company, L.P. · filed 2021-08-27(a)(1)
The Court holds as a matter of law that TAG Electric’s response was sufficient to constitute prompt remedial action.Read the full opinion on CourtListener →
Section 2000e-2(a) covers a racially hostile work environment; mockery of a coworker’s accent can constitute race-based conduct.
Ki v. Nuclear Regulatory Commission · filed 2021-08-30(a)
Mocking or making derogatory comments regarding a colleague’s accent is explicitly race-based conduct.Read the full opinion on CourtListener →
Title VII requires a hostile work environment plaintiff to show objectively and subjectively offensive harassment based on a protected trait or protected behavior, conduct that is severe or pervasive, and a basis for employer liability.
Mahran v. Advocate Christ Medical Center · filed 2021-09-01(a)
Mahran brought this claim under three statutes— Title VII, 42 U.S.C. § 1981, and the IHRA—but the legal standard is the same under all three. To prevail, a plaintiff must show that “(1) the work environment was both objec- tively and subjectively offensive; (2) the harassment was based on membership in a protected class or in retaliation for protected behavior; (3) the conduct was severe or perva- sive; and (4) there is a basis for employer liability.”Read the full opinion on CourtListener →
Section 2000e-2 permits a sex-based hostile work environment claim when harassment is severe or pervasive enough to make the workplace abusive to both the employee and a reasonable person.
Miller v. Mediko, Inc. · filed 2021-09-03(a)(1)
In these circumstances, there is an issue of fact as to whether Miller perceived, and a reasonable person would perceive, the environment to be abusive and hostile.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a hostile work environment to be based on a protected characteristic and to involve severe or pervasive harassment.
Chen v. Yellen · filed 2021-09-16(a)(1)
Here, Chen has produced no evidence that any harassment was based on her race or national origin. Even if she had, she has not shown that she was subjected to any severe or pervasive harassment.Read the full opinion on CourtListener →
Section 2000e-2 requires sex-based harassment to be sufficiently severe or pervasive to support a Title VII hostile work environment claim.
Shkoza v. NYC Health and Hospital Corporation · filed 2021-09-22(a)(1)
The conduct described in Plaintiff’s opposition memorandum, even if inappropriate, is insufficiently severe and continuous to rise to the level of a hostile work environment under Title VII and the NYSHRL.Read the full opinion on CourtListener →
A sex-based hostile work environment claim requires evidence that the employee subjectively believed the harassment was based on sex.
Clemmer v. Evans · filed 2021-09-23
Because I find that there is no evidence Ms. Clemmer had a subjective belief she was harassed based on her sex, I need not consider Judge Evans’s other arguments.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) allows a hostile work environment claim even when the employee supervised some of her alleged harassers.
Powell v. Susdewitt Management, LLC · filed 2021-09-27(a)(1)
At this stage of the proceedings, based on the allegations in the complaint, the fact that Powell may have been a supervisor to some of her harassers does not preclude her claim.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) permits a sexual hostile work environment claim to proceed when genuine factual disputes concern whether the harassment was severe or pervasive and whether the employee suffered a tangible job detriment.
Matthews v. Detroit Public Schools · filed 2021-09-27(a)(1)
Because Matthews has shown that a material issue of fact exists regarding the severity or pervasiveness of the alleged harassment and regarding whether she experienced a tangible job detriment, the Court finds that DPSCD is not entitled to summary judgment with respect to the Title VII hostile work environment claim.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) covers sexual harassment that is severe or pervasive enough to create a hostile work environment; allegations of repeated unwanted touching and an unwanted kiss can plausibly state a claim.
Mitchem v. Sleepcair, Inc. · filed 2021-09-28(a)(1)
At this pleading stage, plaintiff has shouldered her burden to allege plausible hostile work environment claims. Thus, the court declines to dismiss her Title VII and KAAD sexual harassment claims.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) covers a hostile work environment when discriminatory conduct is sufficiently severe or pervasive to alter employment conditions.
Eaton v. Montana Silversmiths · filed 2021-09-28(a)(1)
Hostile work environment falls under the protections of Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e-2(a)(1). ... Therefore, the Court finds Eaton has failed to establish a prima facie case of hostile work environment under Title VII and that summary judgment is appropriate as to Count 5.Read the full opinion on CourtListener →
Section 2000e-2(a) permits a sex-based hostile work environment claim when a reasonable jury could find harassment severe or pervasive enough to alter employment conditions.
MCCRACKEN v. STATE OF INDIANA · filed 2021-09-29(a)
In sum, the Court finds McCracken has produced sufficient evidence to raise a genuine issue as to whether she was subjected to sufficiently severe or pervasive harassment as to alter the conditions of employment and create a hostile work environment.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) covers racial harassment that is sufficiently severe or pervasive to alter the conditions of employment.
Webb v. City of Venice · filed 2021-09-30(a)(1)
Taking into account the time frame, the number of events, their nature, frequency and severity, and the impact on Plaintiff’s ability to work, Plaintiff has presented sufficient evidence to create a fact issue on whether the alleged misconduct was sufficiently severe or pervasive to create a hostile work environment.Read the full opinion on CourtListener →
Section 2000e-2(a) requires a hostile work environment claim based on sex to involve harassment motivated by sex discrimination; jealousy of a relationship or settlement does not suffice.
BISHOP v. CITY OF PHILADELPHIA · filed 2021-09-30(a)
While Bishop argues that either “jealousy of a sexual nature” or jealousy of “all the money she got” from her settlement was the motivation behind the notes, neither forms the basis of a sex discrimination claim.Read the full opinion on CourtListener →
Section 2000e-2 covers sexual harassment that creates a hostile work environment.
Downey v. Earl Johnson and Massachusetts Department of State Police · filed 2021-10-08
Chapter 151B and Title VII delineate two forms of actionable sexual harassment. ... The second form, known as hostile work environment sexual harassment, occurs when an offender’s “sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature” has the “purpose or effect of unreasonably interfering with an individual’s work performance” by creating “an intimidating, hostile, humiliating or sexually offensive work environment.” G.L. c. 151B, § 1(18); 29 C.F.R. § 1604.11(a).Read the full opinion on CourtListener →
Section 2000e-2(a)(1) covers a racially hostile work environment, and two racial slurs directed at an employee by a supervisor can be severe enough to support a claim.
Outley v. City Of Chicago · filed 2021-10-12(a)(1)
Those two slurs alone could sustain a finding that the harassment directed at Outley was severe. ... The City therefore is not entitled to summary judgment on Outley’s hostile work environment claim.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) covers a hostile work environment when harassment is severe or pervasive enough to affect the terms and conditions of employment.
Sheaffer v. Glendale Nissan, Inc. · filed 2021-10-20(a)(1)
Because no reasonable juror could conclude that the alleged sexual harassment Sheaffer experienced was severe or pervasive, Sheaffer’s hostile work environment claim cannot survive summary judgment.Read the full opinion on CourtListener →
Section 2000e-2 permits a racial hostile work environment claim when the alleged conduct is sufficiently severe or pervasive to alter working conditions.
Mitchell v. Wormuth · filed 2021-10-22
Plaintiff need only present a “triable issue of fact” at this juncture—she need not prove her claims to survive a motion to dismiss. ... It remains to be seen whether Plaintiff can prove that she was subjected to verbal or physical conduct based on her race,67 but the Complaint here meets the prima facie test for a hostile work environment on its face.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a hostile work environment claim to plausibly allege sex-based conduct severe or pervasive enough to create a hostile or abusive workplace.
Bar v. Kalitta Charters II, LLC · filed 2021-10-25(a)(1)
Plaintiff has not provided sufficient factual content for the Court to reasonably infer that Defendant’s conduct was severe or pervasive enough to create a sexually hostile or abusive work environment.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits sex discrimination in employment, including sexual harassment and a hostile work environment.
Doe v. New Aspen Management LLC · filed 2021-11-01(a)(1)
Title VII, along with the THRA, prohibits employment discrimination “because of . . . sex.” 42 U.S.C. § 2000e-2(a)(1); see also T.C.A. § 4-21-101(a)(1). These prohibitions also apply to sexual harassment and a hostile work environment.Read the full opinion on CourtListener →
An employer’s response to a customer’s known sexual harassment can independently create a hostile work environment under § 2000e-2(a)(1).
Fried v. Wynn Las Vegas, LLC · filed 2021-11-18(a)(1)
But a reasonable factfinder could conclude that the manager’s response to Fried’s report of a customer’s overt sexual proposition subjected Fried to a hostile work environment.Read the full opinion on CourtListener →
A hostile work environment claim requires harassment sufficiently severe or pervasive to create an abusive working environment; offensive but isolated conduct does not suffice.
Middleton v. United Church of Christ Board · filed 2021-11-22(a)(1)
Taking Middleton’s remaining allegations together and as true, the UCC and her supervisor’s actions were unprofessional and at times offensive but fall short of being sufficiently severe or pervasive for her to plausibly plead a hostile work environment under the standard set out in Harris.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires sexual harassment to be severe or pervasive enough to create a hostile work environment.
Jackson v. East Saint Louis Board of Education District 189 · filed 2021-11-22(a)(1)
Because Culver’s conduct cannot be considered severe or pervasive as a matter of law, Defendants are entitled to summary judgment with respect to Jackson’s Title VII sexual harassment claims (Count I).Read the full opinion on CourtListener →
Section 2000e-2 requires evidence that workplace harassment was based on race to establish a racially hostile work environment.
Hearn v. DeJoy · filed 2021-11-23
Because Hearn introduced no evidence that her coworker yelled at or poked her because she was Black, the conflict that she describes cannot establish a hostile work environment under Title VII.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) covers sexual-orientation harassment, but a hostile-work-environment claim requires harassment severe or pervasive enough to alter employment conditions.
Welch, Jayte v. ABR Staffing · filed 2021-11-24(a)(1)
As a result, plaintiff’s general allegation that some other people may have at some point “ridiculed” homosexuals does not by itself support an inference that the comments were so severe or pervasive to have been intolerable.Read the full opinion on CourtListener →
Section 2000e-2(a) requires a hostile work environment claim to allege discrimination because of sex; sexually explicit music played to all employees without sex-based targeting does not suffice.
Sharp v. S&S Activewear, L.L.C. · filed 2021-12-08(a)
But Plaintiffs fail to state an actionable Title VII claim because they fail to allege that the offending conduct was discriminatory.Read the full opinion on CourtListener →
Section 2000e-2 permits a male employee to bring a sex-based hostile work environment claim.
Taylor v. Go-Getters, Inc. · filed 2021-12-09(a)(1)
His male gender does not foreclose such a claim.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) allows a hostile work environment claim based on unwelcome harassment tied to an employee’s protected status.
Desport v. Shamrock Energy Solutions, LLC · filed 2021-12-14(a)(1)
Given the undisputed facts, Plaintiff has made a prima facie showing as to each prong. ... These facts are sufficient to meet the second and third prongs of a hostile work environment claim.Read the full opinion on CourtListener →
Section 2000e-2 requires sex-based conduct to be sufficiently severe or pervasive to support a hostile work environment claim.
Connelly v. State of Maryland Department of Human Services · filed 2021-12-20(a)
While these questions made Plaintiff feel “extremely harassed,” (id. J 35), the Court cannot conclude that these general allegations plead an objectively hostile work environment.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a hostile work environment claimant to allege that discrimination detrimentally affected the claimant and would detrimentally affect a reasonable person in like circumstances.
OVALLE v. HARRIS BLACKTOPPING, INC. · filed 2021-12-22(a)(1)
But the Workers do not allege facts allowing us to infer this alleged discrimination detrimentally affected Workers and the discrimination would detrimentally affect a reasonable person in like circumstances. ... We dismiss Workers’ hostile work environment and constructive discharge claims without prejudice to timely amend to plead separate claims consistent with the Law.Read the full opinion on CourtListener →
A hostile work environment claim requires evidence that the conduct was subjectively and objectively offensive, based on membership in a protected class, and severe or pervasive.
Geng v. Del Toro · filed 2021-12-23(a)(1)
To survive summary judgment on a hostile-work-environment claim, Geng needed to present evidence that her work environment was subjectively and objectively offensive, ... the harassment was based on membership in a protected class, and the conduct was severe or pervasive. Abrego, 907 F.3d at 1015. No reasonable jury could make any of these findings.Read the full opinion on CourtListener →
Section 2000e-2(a) prohibits race-based workplace harassment that is severe or pervasive when there is a basis for employer liability.
Cooper v. Pennsylvania Human Relations Commission · filed 2022-01-05(a)
Thus, given these procedural and substantive hurdles, the plaintiff’s hostile workplace claim fails, as it is currently pleaded, and the defendant is entitled to summary judgment on this claim.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a hostile work environment claim to connect the alleged abuse to a protected characteristic.
Zweibelson v. Hartford · filed 2022-01-21(a)(1)
Critically, SGT Zweibelson does not plead any facts suggesting a causal relationship between the City’s actions and his membership in a protected class. Therefore, his hostile work environment claim under Title VII fails.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) does not cover workplace harassment unless it is alleged to relate to a class protected by Title VII.
Gaines v. Stenson · filed 2022-01-26(a)(1)
While a hostile workplace can constitute a form of racial harassment, a hostile workplace is not ipso facto racial discrimination when it is not pled as such.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) permits a hostile work environment claim to proceed when repeated racial stereotyping and demeaning conduct plausibly make employment conditions abusive.
Dwayne v. Azar · filed 2022-02-02(a)(1)
Parris has alleged, inter alia, repeated use of offensive racial stereotypes by his supervisors, repeated insults through being prohibited to talk at meetings, repeated differential treatment regarding work-related requests, and frequent changes to his assignments in a manner designed for him to fail. Based on these allegations, a jury could conclude that Parris was subjected to sufficiently severe and pervasive insult and ridicule such that the conditions of his employment were abusive.Read the full opinion on CourtListener →
Section 2000e-2 requires a hostile work environment claimant to allege harassment because of a protected class.
Prosa v. Austin III · filed 2022-02-08
To satisfy the second element of a hostile work environment claim, the plaintiff must allege that she was harassed or otherwise discriminated against “because of” her protected class.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires sex-based harassment to be objectively severe or pervasive enough to alter employment conditions for a hostile work environment claim.
Eaves v. Cajun Operating Company · filed 2022-02-14(a)(1)
Assuming without deciding that she timely filed her EEOC charge, the Plaintiff has failed to allege the objective severity of harassment required to sustain a hostile work environment claim.Read the full opinion on CourtListener →
Section 2000e-2(a) requires a hostile work environment claim to allege harassment based on a protected characteristic, such as race or religion.
Newell v. Acadiana Planning Commission Inc · filed 2022-02-22(a)
Merely offensive conduct, even if severe, is not actionable under Title VII unless it relates to a protected characteristic—here, race or religion.Read the full opinion on CourtListener →
Section 2000e-2(a) prohibits sex-based harassment that is severe or pervasive enough to alter the conditions of employment.
Dittmar v. City of North Las Vegas · filed 2022-02-24(a)
Assuming without deciding that the unwelcome commentary was related to Dittmar’s sex, the infrequency, temporal isolation, and low severity of each comment preclude me from finding that they altered the conditions of Dittmar’s employment.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a hostile work environment plaintiff to show that the alleged harassment was based on sex; speculation about the harasser’s motive is insufficient.
Atkins v. Smyth County Virginia School Board · filed 2022-02-25(a)(1)
Atkins’ claim fails as a matter of law because she has not met her burden of proof as to the second element — that Leonard’s behavior toward her was based on her sex.Read the full opinion on CourtListener →
Section 2000e-2 protects employees from racial harassment that creates a hostile work environment; allegations of racial hostility and an inadequate employer response can make such a claim plausible at the pleading stage.
LEE v. MAINE PUBLIC EMPLOYEES RETIREMENT SYSTEM · filed 2022-03-02
There is no doubt that Plaintiff, who is Asian-American, is a member of a protected class. See 42 U.S.C.A. § 2000e-2 (listing race as a protected classification); see also 5 M.R.S. § 4572 (same). Her allegations, if true, would show that she was subjected to unwelcome treatment based on her race insofar as she was exposed to multiple incidents of racial hostility.Read the full opinion on CourtListener →
A hostile work environment claim requires facts showing intentional discrimination because of sex; offensive epithets alone do not establish that element.
CHERKASKY v. BOYERTOWN AREA SCHOOL DISTRICT · filed 2022-03-02(a)(1)
Thus, Cherkasky has not alleged facts sufficient to meet the first element of a hostile work environment based on sex because sex was not a substantial factor in the alleged harassment.Read the full opinion on CourtListener →
An isolated incident of sexual harassment must be extremely serious to establish a hostile work environment under § 2000e-2(a)(1).
Lynch v. Fluor Federal Petroleum Operation, LLC · filed 2022-03-07(a)(1)
Sclafani’s alleged conduct here, though inappropriate, is clearly less severe than the conduct in Paul, Gibson, and Hockman, and therefore is not sufficient to establish a hostile work environment under Fifth Circuit precedent.Read the full opinion on CourtListener →
Allegations of racial and gender harassment and more favorable treatment of white male coworkers can plausibly state Title VII disparate treatment and hostile work environment claims.
McClain v. Ford Motor Company · filed 2022-03-07(a)(1)
Plaintiff’s Proposed First Amended Complaint states that she is an African American woman, provides examples of gendered and racialized harassment by fellow employees, including names and approximate dates, and alleges that her white male harassers were subject to more favorable treatment from supervisors despite her many complaints. At the pleading stage, these assertions are sufficient to plausibly allege claims for disparate treatment and hostile work environment.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires sex-based harassment to be severe or pervasive enough to create an objectively hostile work environment.
Marchello v. Xcel Energy, Inc. · filed 2022-03-11(a)(1)
In comparison, Plaintiff’s incidents were mainly “offensive utterances” spread over a ten-year period. The evidence that Plaintiff provides in her response, in the totality of the circumstances, is not sufficient for a reasonable jury to find that the environment was objectively hostile.Read the full opinion on CourtListener →
Race-based harassment must be severe or pervasive enough to alter the conditions of employment to support a hostile work environment claim.
Andrews v. Virginia Polytechnic Institute · filed 2022-03-15
Viewing the evidence in the light most favorable to Andrews and assuming the statements and conduct she describes were in fact harassment, those “handful of incidents” over a five-year period fail to support a finding that such harassment was “pervasive.”Read the full opinion on CourtListener →
Section 2000e-2(a) permits a race based hostile work environment claim when individually minor incidents together form a broader pattern of harassment.
Poole v. Garland · filed 2022-03-17(a)
Allegations of incidents that alone might be relatively minor but—when taken together—assert a broader pattern can be sufficient to support a hostile work environment claim.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires harassment to be severe or pervasive enough to create an actionable hostile work environment.
Kilpatrick v. HCA Human Resources LLC · filed 2022-03-22(a)(1)
Considering the totality of the conduct alleged, it is neither severe enough nor pervasive enough to create an actionable hostile work environment.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires racial harassment to be severe or pervasive enough to alter the conditions of employment for a hostile work environment claim.
Coleman v. Red Lion Controls, Inc. · filed 2022-03-24(a)(1)
Coleman has not met his burden to establish a claim for hostile work environment under Title VII or the PHRA because the mistreatment he experienced was not “severe or pervasive” enough “to alter the conditions of” his employment.Read the full opinion on CourtListener →
A hostile work environment claim requires facts connecting the alleged mistreatment to a protected characteristic such as race or color.
Rosero v. Johnson, Mirmiran & Thompson, Inc. · filed 2022-03-28(a)
Rosero’s hostile work environment claim fails, though, because he does not include sufficient factual allegations to connect that treatment with his race or color.Read the full opinion on CourtListener →
A sufficiently pleaded hostile work environment claim can proceed under Title VII.
Friederick v. Passfeed, Inc. · filed 2022-03-31(a)(1)
Plaintiff has plausibly alleged that she was subjected to a hostile work environment under all three statutes.Read the full opinion on CourtListener →
A race-based hostile work environment claim requires evidence that the harassment was based on race.
Gaulden v. Philips North America LLC. · filed 2022-04-04(a)(1)
Based on these principles, the court finds that the plaintiff fails to establish that any harassment she experienced was “based on race.”Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires sex-based harassment to be severe or pervasive to support a hostile work environment claim.
Pascua v. Jewel Food Stores, Inc. · filed 2022-04-07(a)(1)
Even construing the record in the light most favorable to plaintiff, the acts of which she complains lack the severity or pervasiveness required to establish a hostile work environment.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) covers racially hostile work environments, but isolated harassment does not establish a claim when it is neither severe nor pervasive and the employer responds promptly.
Lockett v. Webco Industries · filed 2022-04-21(a)(1)
We agree with the district court that Mr. Lockett’s harassment claim fails for two reasons. First, the alleged racial harassment was neither pervasive nor severe; to the contrary, there was a single incident of alleged racial enmity and one racial slur. Second, Webco was not negligent; rather, the company promptly investigated both incidents and suspended Todd for two days without pay for uttering the “n” word.Read the full opinion on CourtListener →
Sex-based harassment must be severe or pervasive enough to create an objectively hostile or abusive working environment to support a claim under § 2000e-2(a)(1).
Chambers v. Bimbo Bakery · filed 2022-04-29(a)(1)
Even though Plaintiff has alleged a link between the harassment she experienced and her sex, the Amended Complaint’s allegations fail to suggest conduct that is severe enough to support a hostile work environment claim.Read the full opinion on CourtListener →
Section 2000e-2 requires a hostile work environment plaintiff to allege harassment because of a protected characteristic.
Gaines v. Baltimore City, Maryland · filed 2022-05-09(a)(1)
To satisfy the second element of a hostile work environment claim, the plaintiff must allege that she was harassed or otherwise discriminated against “because of” her protected class.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) covers sex-based harassment that is sufficiently severe or pervasive to create a hostile work environment.
Plain v. McDonald's Corporation · filed 2022-05-10(a)(1)
The court finds Plaintiff has cited evidence from which a reasonable jury could find that Plaintiff was subjected to conditions sufficiently severe and pervasive to support a claim of sex discrimination.Read the full opinion on CourtListener →
A race-based hostile work environment claim under § 2000e-2(a)(1) can proceed when the allegations plausibly show that unwelcome treatment was based on race.
Williams v. Ellicott Dredges, LLC · filed 2022-06-06(a)(1)
The Court thus concludes that Williams’ race-based harassment claims adequately allege that the unwelcome treatment she experienced was based on her race.Read the full opinion on CourtListener →
A sex-based hostile work environment claim requires facts linking the alleged mistreatment to sex; an offensive epithet alone does not establish that link.
CHERKASKY v. BOYERTOWN AREA SCHOOL DISTRICT · filed 2022-06-06(a)(1)
In sum, the students’ use of the word “bitch,” even in light of the other alleged misbehavior, does not support a claim for discrimination based on sex as a matter of law.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) allows discriminatory comments and facially neutral mistreatment to be considered together when deciding whether a hostile work environment claim can proceed.
Thange v. OXFORD GLOBAL RESOURCES, LLC · filed 2022-06-07(a)(1)
Viewing the record in the aggregate, the Court finds that Plaintiff has demonstrated a genuine issue ... of material fact as to whether Adkins’s comments were motivated by animus based on race, religion, or national origin. Thus, a reasonable factfinder could conclude that all of the alleged mistreatment, including the facially neutral conduct, was related to Plaintiff’s race, religion, or national origin.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires harassment to be sufficiently severe or pervasive to support a hostile work environment claim.
Louis v. Window Rock Unified School District · filed 2022-06-14(a)(1)
Absent further evidence, the Court finds no reasonable juror could conclude the text messages were sufficiently severe or pervasive to support a hostile work environment claim.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires racial harassment to be sufficiently severe or pervasive to support a hostile work environment claim; a single remark generally does not suffice.
Sims v. University of Maryland Medical System Corporation · filed 2022-06-23(a)(1)
The comment comparing Dr. Sims’s aggressiveness to that of an “average Black woman” arose out of a single disagreement early in Dr. Sims’s multi-year tenure at the Medical Center, which generally does not establish the existence of a hostile work environment.Read the full opinion on CourtListener →
Section 2000e-2(a) requires harassment to be severe or pervasive to support a hostile work environment claim; isolated teasing and flirtation do not meet that standard.
Karpaitis v. Mandal's, Inc. · filed 2022-07-05(a)
Thus, the Court finds that the allegations do not rise to the level of “severe or pervasive” conduct required to maintain a hostile work environment claim.Read the full opinion on CourtListener →
A sex-based hostile work environment claim can proceed when the evidence creates a genuine dispute over whether the alleged conduct was sexual in nature.
Colo v. NS Support, LLC · filed 2022-07-07(a)(1)
In so doing, the Court finds Colo has identified evidence sufficient to give rise to a genuine dispute of material fact on the first element of her claim for hostile work environment based on sex. Whether a jury finds that the evidence proves the alleged conduct was of a sexual nature is a factual determination that must be made at trial.Read the full opinion on CourtListener →
Section 2000e-2(a) requires harassment to be objectively severe or pervasive enough to alter employment conditions for a hostile work environment claim.
Branaman v. Pettway · filed 2022-07-20(a)
As such, based on this record, Watts’s behavior does not rise to the objective severity of conduct necessary for a Title VII harassment claim.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) allows a religious hostile work environment claim to proceed when the alleged conduct plausibly interfered with the employee’s work and was linked to religion.
Landa v. University of Maryland, College Park · filed 2022-07-22(a)(1)
Taken together, at this stage of the case, these circumstances plausibly suggest that Dr. Landa was subjected to a hostile work environment because of religious discrimination or in retaliation for engaging in protected activity.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits racial harassment that cumulatively creates a hostile work environment and materially changes the terms or conditions of employment.
Webb v. City of Venice · filed 2022-07-27(a)(1)
An employer violates Title VII when it discriminates against an employee by actions that cumulatively create a hostile work environment that brings about a material change in the terms and conditions of employment.Read the full opinion on CourtListener →
Large gaps between alleged incidents weigh against finding that racial harassment was pervasive enough to create a hostile work environment.
McIver v. Bridgestone Americas, Inc. · filed 2022-08-02(a)(1)
Large temporal gaps suggest occasional problems, not pervasive ones.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) allows a racial hostile work environment claim when the alleged harassment, viewed in context, plausibly stems from race.
Countryman-Roswurm v. Wichita State University · filed 2022-08-02(a)(1)
While most of these allegations are race-neutral, Dr. Besthorn’s alleged belief that “Native women are known for trading sex to get what they want” suffices to push plaintiff’s racial harassment claim over the line separating plausible and implausible claims.Read the full opinion on CourtListener →
Section 2000e-2(m) requires facts supporting a plausible inference that race or sex motivated the alleged harassment.
Carroll v. Amazon Data Services, Inc. · filed 2022-08-08(m)
For the purposes of this element and the allegations in the Complaint,2 the Court examines whether Plaintiff pleads facts to support that her race or sex were motivating factors in the defendant’s conduct, and specifically if that factual support raises the allegation above a speculative level. ... Considering the relevant facts in the light most favorable to Plaintiff, the allegations in the Complaint are conclusory and merely speculate that Plaintiff’s race or sex were a motivating factor in Defendant’s conduct.Read the full opinion on CourtListener →
Section 2000e-2(a) permits a hostile work environment claim when alleged sexual harassment is sufficiently severe and the employer negligently delays responding after notice.
Strobel v. Westfield State University · filed 2022-08-09(a)
Considering the totality of the circumstances alleged – the unwanted grabbing, the incident involving another employee, and the psychological and physical manifestations of the stress – a factfinder could conclude that the harassment Plaintiff alleges she experienced was sufficiently severe to create a hostile work environment. ... In view of the considerable amount of time that passed between Plaintiff's notice of sexual harassment and Defendant's response and the allegation of prior knowledge, Plaintiff has pled sufficient facts to survive a motion to dismiss.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires sexual conduct to be sufficiently severe or pervasive to create an actionable hostile work environment.
Brooks v. Fast Park and Relax · filed 2022-08-15(a)(1)
In this case, Brooks’s Amended Complaint fails to allege conduct that is “sufficiently severe or pervasive” to constitute an actionable “abusive work environment.”Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits a sex-based hostile work environment when harassment is severe or pervasive enough to create an abusive working environment.
Vidrine v. Guillot · filed 2022-08-18(a)(1)
Appellants failed to show a genuine dispute of material fact regarding whether they were subject to severe or pervasive harassment. Accordingly, the district court did not err in granting summary judgment on the hostile work environment claim.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) covers a sex-based hostile work environment when discriminatory conduct, viewed cumulatively, alters employment conditions.
LAUTO v. DOVER PUBLIC SCHOOL DISTRICT · filed 2022-08-24(a)(1)
Here, Plaintiff’s claims for hostile work environment under Title VII and the NJLAD are sufficiently pled.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) permits a racially hostile work environment claim when the alleged discrimination plausibly amounts to severe or pervasive harassment tolerated by the employer.
Robards v. BLK Out Transport · filed 2022-08-25(a)(1)
Taking the facts in Plaintiffs’ Compliant as true, see Total Benefits Plan Agency, Inc., 552 F.3d at 434, Plaintiffs have successfully established a plausible claim for a hostile and discriminatory work environment under Title VII or KRS Chapter 344.Read the full opinion on CourtListener →
Section 2000e-2 prohibits sex discrimination that creates a hostile work environment when the discrimination is severe or pervasive.
HENRICH v. HENKELS & MCCOY, INC. · filed 2022-08-26
The Court concludes that Plaintiff has presented sufficient evidence for a reasonable jury to infer that she was subjected to severe or pervasive gender discrimination that gave rise to a hostile work environment in violation of Title VII.Read the full opinion on CourtListener →
Section 2000e-2 requires evidence of severe or pervasive sex-based conduct that creates an offensive or abusive work environment to sustain a hostile work environment claim.
La Verne Foster v. DeJoy · filed 2022-08-31
Regardless, to survive summary judgment on this claim, she needed to present sufficient evidence to create a fact question over whether because of her sex, she was subject to severe or pervasive conduct that created an offensive or abusive work environment.Read the full opinion on CourtListener →
A single appearance of a perceived noose, with no other overt racial harassment, did not establish a hostile work environment under § 2000e-2(a)(1).
Lemonia v. Westlake Management Services Inc · filed 2022-09-19(a)(1)
While other cases have also emphasized the plaintiff’s failure to complain, “the single appearance of what appeared to plaintiff to be a noose . . . without any previous or subsequent instances of overtly racial harassment or discrimination, falls far short of establishing an actionable hostile work environment claim[.]” Morris, 2018 WL 1726257 at *10. Accordingly, plaintiff cannot meet the fourth element of his claim and Westlake is entitled to summary judgment.Read the full opinion on CourtListener →
Section 2000e-2 requires harassment to be objectively severe or pervasive to support a hostile work environment claim.
Brunson v. Johns Hopkins Community Physicians, Inc. · filed 2022-09-21
Under the totality of the circumstances, Brunson has not identified the type of conduct that is severe or pervasive enough to create an objectively hostile workplace.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires conduct to be severe or pervasive to constitute a hostile work environment.
Jemmott v. New York City Health and Hospitals Corporation · filed 2022-09-26(a)(1)
No reasonable jury could find this conduct to constitute severe or pervasive harassment.Read the full opinion on CourtListener →
Section 2000e-2(a) requires a hostile-work-environment plaintiff to plausibly allege that the harassment was motivated by sex discrimination.
Verdu v. Princeton University Trustees · filed 2022-09-27(a)
However, Verdu never plausibly alleges that Im’s pressure campaign and the “hostile work environment” that purportedly resulted from it were motivated by sex discrimination.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a hostile work environment claim based on race or gender to involve harassment tied to that trait that is severe or pervasive enough to alter working conditions.
Scaife v. DVA · filed 2022-09-27(a)(1)
In short, based on all the evidence, Scaife has failed to show harassment based on gender or that the alleged conduct was severe or pervasive.Read the full opinion on CourtListener →
Unwanted sexual touching by a coworker can be severe enough to support a hostile work environment claim under subsection (a)(1).
Young v. Housing Authority of Baltimore City · filed 2022-09-27(a)(1)
Accordingly, I find that Plaintiff has established a genuine dispute of material fact as to whether Mr. Reaves’ conduct was sufficiently severe or pervasive.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires sexual harassment to be severe or pervasive enough to alter the conditions of employment for a hostile work environment claim.
Owens v. Forest River Manufacturing, LLC · filed 2022-09-28(a)(1)
The Court cannot find that these events constitute pervasive harassment under Title VII.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a hostile work environment claimant to show race-based harassment that was severe or pervasive and for which the employer is liable.
Bowie v. Oakland Community College · filed 2022-09-28(a)(1)
The Court finds, however, that Bowie has not demonstrated a genuine issue of material fact that the alleged harassment was race-based, or that the harassment was severe or pervasive, or that the college is liable for any coworker harassment.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) covers sex-based hostile work environments when harassment is sufficiently severe or pervasive to alter the conditions of employment.
Little v. City of New York · filed 2022-09-28(a)(1)
Plaintiff’s allegations that Pantin touched her “upper arm area” on three occasions and “kept looking at [her] body” on at least one other occasion, Opp’n 8; SAC 4, when viewed in the light most favorable to her, do not constitute allegations of conduct “‘sufficiently severe or pervasive to alter the conditions of the victim’s employment and create an abusive working environment.’” Alfano, 294 F.3d at 373 (citation omitted).Read the full opinion on CourtListener →
Section 2000e-2(a) requires severe or pervasive discriminatory treatment to establish a hostile work environment.
Sousa v. Amazon.com, Inc. · filed 2022-09-29(a)
Sousa alleges neither severe nor pervasive discriminatory treatment.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires harassment to be severe or pervasive enough to create a hostile work environment.
Stein v. Wilkinson · filed 2022-09-29(a)(1)
The two occasions where Officer Eisenmann was physically present at the workplace and one email sent from him to the plaintiff do not give rise to the severe or pervasive conditions necessarily to establish a hostile work environment.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a hostile work environment claimant to show unwelcome harassment because of sex that affects a term, condition, or privilege of employment.
Fugarino v. Milling Benson Woodward L.L.P. · filed 2022-10-11(a)(1)
Under Title VII, to prevail on a hostile work environment claim, at trial Plaintiff must establish that: (1) she belongs to a protected group; (2) she was subjected to unwelcome sexual harassment; (3) the harassment complained of was because of her sex; and (4) the harassment affected a term, condition, or privilege of her employment.Read the full opinion on CourtListener →
Section 2000e-2(a) permits a sex-based hostile work environment claim when severe or pervasive harassment tied to sexual orientation is attributable to the employer.
Hester v. Prince George's County Public Schools · filed 2022-10-12(a)
Hester has therefore plainly alleged sufficient facts to support a claim that the hostile work environment was based on sex.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) does not make occasional offensive sex-related remarks actionable unless they are severe or pervasive enough to affect employment.
Lavelle v. CL West Management LLC · filed 2022-10-18(a)(1)
While offensive, these occasional statements do not rise to the level of severity to rise a genuine issue of material fact as to a Title VII violation that interferes unreasonably with Plaintiff’s employment.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits sex-based harassment that is sufficiently severe or pervasive to alter the conditions of employment.
Whatley v. Hopewell · filed 2022-10-19(a)(1)
For harassment to affect a term, condition, or privilege of employment, the conduct at issue must be “sufficiently severe or pervasive to alter the conditions of the victim’s employment and create an abusive working environment.”Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires a hostile work environment plaintiff to show that the harassment was based on sex and created a hostile work environment.
McPherson v. Metropolitan Security Services, Inc. · filed 2022-10-24(a)(1)
The evidence that Plaintiff has marshalled in support of her claim for sex-based harassment leading to a hostile work environment cannot support the third and fourth elements of a prima facie hostile work environment claim.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) covers sexual harassment that is severe or pervasive enough to alter the conditions of employment.
Lintzenich v. PFTN Columbia, LLC · filed 2022-10-25(a)(1)
The nature of the messages, which could be characterized as lewd, vulgar, and even portending sexual violence, and that the messages persisted for a number of months, is such that a reasonable jury could find the harassment severe and pervasive enough that it altered the terms and conditions of her employment.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) covers race- or sex-based harassment that is sufficiently severe or pervasive to create a hostile work environment.
Cuthbertson v. First Star Logistics, LLC · filed 2022-11-01(a)(1)
Because Plaintiff cannot show that the conduct complained of was sufficiently severe or pervasive to create a hostile work environment, Defendant is entitled to summary judgment.Read the full opinion on CourtListener →
Section 2000e-2(a) requires a hostile work environment claim to allege disadvantageous employment conditions based on race, color, religion, sex, or national origin.
Singleton v. McDonald · filed 2022-11-04(a)
To state a claim under Title VII, the critical issue is whether employees are exposed to disadvantageous terms or conditions of employment based on their race, color, religion, sex, or national origin. ... Again, Plaintiff does not allege any facts suggesting that her employer took unfavorable actions against her based on her membership in any of these protected classes. She fails to state a plausible claim for relief under Title VII.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) permits a race-based hostile work environment claim when the evidence raises a genuine dispute about whether the employer’s conduct was based on race.
Taylor v. Kaiser Foundation Health Plan of Colorado · filed 2022-11-10(a)(1)
The Court finds that Plaintiff has sufficiently raised a genuine dispute of material fact regarding whether Kaiser’s conduct toward her was based on her race and whether Kaiser knew of the alleged harassment of Ms. Taylor.Read the full opinion on CourtListener →
Section 2000e-2(a) permits a race-based hostile work environment claim based on repeated racial harassment even when the misconduct is not daily.
Laurent-Workman v. Wormuth · filed 2022-11-29(a)
But daily hostility is not the essence of a Title VII harassment claim. Our focus remains on the discriminatory character, severity, and consistency of the harassment.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) allows a religious hostile work environment claim based on allegations that an employee was treated more harshly than coworkers because of her religion.
JOSHI v. PUBLIC CONSULTING GROUP LLC · filed 2022-11-30(a)(1)
Indeed, the Court finds that Plaintiff clearly alleges that the differential treatment she received was based on religion.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires an employee alleging racial harassment to show that the conduct would not have occurred but for the employee’s race.
Brown v. Bratton · filed 2022-11-30(a)(1)
An employee is harassed or otherwise discriminated against because of his race if, “but for” the employee’s race, he would not have faced such conduct.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) permits a hostile work environment claim based on allegations of pervasive sexual harassment.
Stripling v. Ingram Barge Company, LLC · filed 2022-12-06(a)(1)
Defendant’s argument focusing on discrete events ignores the alleged pervasiveness and severity of the conduct alleged. Plaintiff claims that she was subjected to offensive and harassing conduct “constantly” and that she became concerned for her safety and ultimately insisted on leaving the boat. At this stage, Plaintiff’s allegations are sufficient to state a plausible claim for sexual harassment that created a hostile work environment.Read the full opinion on CourtListener →
Section 2000e-2(a)(1) prohibits a racially hostile work environment when the conduct is severe or pervasive enough to alter the conditions of employment.
Davis v. Kendall · filed 2022-12-14(a)(1)
To the extent that Plaintiff argues that his workplace was hostile because of his transfer from a temporary lead position to the accounting division, his supervisors’ modifications of certain job requirements to “deceive” him, and his supervisors’ efforts to block him from serving as a “team lead” by withholding certain reports, the Court finds that these allegations are not severe or pervasive enough to alter Plaintiff’s conditions of employment and create an abusive work environment.Read the full opinion on CourtListener →
Section 2000e-2(a) prohibits race-based harassment severe or pervasive enough to alter the conditions of employment.
Miller v. Johnson · filed 2022-12-15(a)
Title VII makes it “an unlawful employment practice for an employer” to “discriminate against any individual with respect to” the “terms, conditions, or privileges of employment, because of such individual's race, color, religion, sex, or national origin.” 42 U.S.C. § 2000e–2(a). ... Given these allegations, Miller adequately demonstrates that the harassment was of “such severity ….as to pollute the working environment.”Read the full opinion on CourtListener →
Section 2000e-2(a)(1) requires sex-based harassment to be severe or pervasive enough to alter employment conditions for a hostile work environment claim.
Pratt v. Wisconsin Aluminum Foundry · filed 2022-12-20(a)(1)
Pratt has not plausibly pleaded the third element, that the harassment was severe or pervasive enough to alter the conditions of employment. Thus, she has failed to plead an adverse employment action as to that claim.Read the full opinion on CourtListener →
Notes 6901–7050 of 12,593, oldest cases first.
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