42 U.S.C. § 2000e-2

Section 2000e-2(a)(1) permits a sexual harassment claim when the evidence could allow a jury to find a hostile work environment.

Gazaway v. Rims USA, LLC d/b/a RNR Tire Express · filed 2022-12-22(a)(1)

After reviewing the evidence in the light most favorable to Plaintiff, the Court concludes that Plaintiff has presented sufficient facts such that a reasonable jury could conclude she was subjected to unlawful sexual harassment.

Section 2000e-2(a)(1) requires evidence that race or color based harassment was severe or pervasive enough to alter the conditions of employment.

Bitsoi v. De La Vega · filed 2023-01-09(a)(1)

In sum, the factual evidence in the record does not establish harassment that was pervasive or severe enough to alter the terms, conditions, or privilege of Plaintiff’s employment, or that the harassment stemmed from racial-, color-, or age-based animus. Accordingly, Defendant is entitled to summary judgment on the hostile work environment claim.

Section 2000e-2(a)(1) permits a hostile work environment claim to proceed when the complaint plausibly alleges severe or pervasive harassment based on sex and a basis for employer liability.

ARNOLD v. MILLER · filed 2023-01-11(a)(1)

But at this juncture, Mr. Arnold has sufficiently pleaded a hostile work environment claim so Kroger's motion must be DENIED.

Section 2000e-2(a)(1) requires a racial hostile work environment claim to plausibly allege that the harassment stemmed from racial animus; a bare assertion that it was race based is insufficient.

McCray v. United States Department of Veterans Affairs, Secretary of · filed 2023-01-12(a)(1)

Unfortunately for plaintiff, this conclusion—without more—can’t suffice to support a plausible inference that the alleged “harassment was racial or stemmed from racial animus.” ... The court thus grants defendant’s Motion to Dismiss this claim.

Section 2000e-2(a)(1) requires evidence that alleged workplace harassment was based on a protected trait; unfair treatment alone does not establish a hostile work environment.

DeSantis v. Mayor and City Counsel of Baltimore · filed 2023-01-12(a)(1)

However, even accepting each of Plaintiff’s assertions as completely true, there is insufficient evidence to support a jury finding that Plaintiff’s asserted mistreatment was because of his race, sex, or age.

Section 2000e-2(a)(1) requires evidence that alleged workplace harassment was based on protected group membership to support a hostile work environment claim.

Butler v. Collins · filed 2023-01-19(a)(1)

No evidence in the record shows Plaintiff was subjected to unwelcome harassment based on her protected group membership as a black woman. After review of the record, the Court has found no evidence that would raise a genuine issue of material fact as to any of Plaintiff’s allegations of hostile work environment. Thus, the record is devoid of any evidence of the third through fifth essential elements of Plaintiff’s hostile work environment claims. ... The Court dismisses Plaintiff’s hostile work environment claims based on 42 U.S.C. § 1981 and Title VII (Counts 10 and 13).

Race-based harassment under Title VII requires conduct severe or pervasive enough to affect a term, condition, or privilege of employment.

Rimson v. Amazon.com, Inc. · filed 2023-01-26(a)(1)

To establish racial harassment under Title VII and the MHRA, Plaintiff must prove (1) he is a member of a protected group; (2) he was subject to unwelcome harassment; (3) the harassment was because of his race; (4) the harassment was sufficiently severe or pervasive to affect a term, condition, or privilege of employment; and (5) the employer knew or should have known of the harassment and failed to take proper remedial action. ... Here, evidence in the record would not permit a jury to conclude that Plaintiff experienced harassment so severe and pervasive as to change the terms or conditions of his employment.

Section 2000e-2(a)(1) requires an employee alleging a hostile work environment based on coworker harassment to show that the employer knew or should have known about the harassment and failed to act.

Ramoni v. Cuyahoga Metropolitan Housing Authority · filed 2023-01-30(a)(1)

Even taking this as true, Ramoni has failed to establish a prime facie case of hostile work environment because it is undisputed that CMHA was never made aware of the “ridicule by his coworkers regularly because of his African accent.”

Section 2000e-2(a)(1) prohibits sexual harassment that is severe or pervasive enough to create a hostile work environment.

Aponte v. Clinton Street Pizza Inc. · filed 2023-02-07(a)(1)

The Court finds that such allegations of severe and pervasive sexual harassment are more than adequate to state a sexually hostile work environment claim pursuant to Title VII.

Section 2000e-2(a) does not make isolated workplace discourtesy actionable when it does not adversely affect an employee’s status or interfere with her work performance.

Edwards v. Pennsylvania Human Relations Commission · filed 2023-02-10(a)

And Edwards has not shown either episode “adversely affected” her “status as an employee,” see 42 U.S.C. § 2000e-2(a), or “interfere[d] with [her] work performance,” see Harris, 510 U.S. at 168.

Section 2000e-2(a) permits a racial hostile work environment claim to proceed when repeated race-based comments, employer inaction, and resulting distress plausibly show severe or pervasive harassment.

Mais v. Albemarle County School Board · filed 2023-02-21(a)

Considering the alleged repeated race-based comments, the School Board’s lack of intervention, and Plaintiff’s emotional and mental distress, Plaintiff has alleged a plausible racial hostile work environment claim under Title VII, which will survive the School Board’s motion to dismiss.

Section 2000e-2(a) allows a race based hostile work environment claim to proceed when the evidence permits a jury to find intentional discrimination and employer liability.

McGLOTTEN v. OMNIMAX INTERNATIONAL, INC. · filed 2023-02-22(a)

Under the federal Title VII of the Civil Rights Act of 1964, “[i]t shall be an unlawful employment practice for an employer to . . . discriminate against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual’s race. . . .” 42 U.S.C. § 2000e-2(a). ... Simply put, McGlotten has marginally produced the requisite evidence to satisfy his burden for Count 1, and so Defendants’ Motion as to Count 1 and its state law analog will be denied.

Section 2000e-2(a)(1) requires harassment to be sufficiently severe or pervasive to make a work environment objectively hostile.

Small v. City of Hollywood · filed 2023-02-28(a)(1)

These comments are merely “[i]solated or sporadic incidents” that are not the concern of Title VII.

Section 2000e-2(a)(1) permits a racially hostile work environment claim to proceed when the alleged conduct plausibly connects the hostility to race.

Walker v. United States Army Secretary of · filed 2023-03-09(a)(1)

The Court also disagrees with Defendant that the Complaint is devoid of facts to support Plaintiff’s claim that the hostile work environment was based on her race. Viewing the facts alleged as true, the hostile work environment was based in part on Defendant’s view of her as an “angry black woman.” Moreover, she alleges that her prior race discrimination complaints caused Defendant to hold this view. She alleges this inappropriate label caused Defendant to discriminate and retaliate against her by creating a hostile work environment. This is sufficient at the pleading stage to demonstrate that her claim is based on her protected status.

Section 2000e-2(a)(1) requires harassment underlying a hostile work environment claim to be motivated by sex.

Overfield v. Kansas, State of · filed 2023-03-09(a)(1)

Viewing the evidence in a light most favorable to Plaintiff, a jury could not reasonably conclude that the conduct Plaintiff complains of was motivated by sex.

Section 2000e-2(a)(1) allows a hostile work environment claim based on sexual orientation to consider derogatory comments directed at others when the plaintiff became aware of them during the alleged hostile environment.

Schlegel v. Finney County, Kansas Board of Commissioners · filed 2023-03-09(a)(1)

Thus, even if Plaintiff did not directly hear Carter making derogatory comments or was herself a victim of discrimination by Carter, his actions towards others could give rise to a claim of hostile work environment.

A racially hostile work environment claim considers only harassment based on the employee’s race.

Grays v. Alejandro N. Mayorkas, Secretary, U.S. Department of Homeland Security · filed 2023-03-16(a)(1)

In assessing Plaintiff’s hostile work environment claim, the court may consider “only harassment based on [P]laintiff’s race.”

A single incident of sexual harassment must be extremely serious to create a hostile work environment under Title VII.

Szyper v. American Medical Response Mid · filed 2023-03-22(a)(1)

As the incident was isolated, the conduct must have been “extremely serious” to create a hostile work environment. Id. Szyper has not shown that.

Section 2000e-2(a)(1) requires evidence that alleged workplace harassment occurred because of a protected characteristic to support a hostile work environment claim.

Williams-Barr v. New York State Department of Corrections and Community Supervision · filed 2023-03-27(a)(1)

However, even viewing the evidence in the light most favorable to the Plaintiff, “[a]part from [Plaintiff’s] unsupported and conclusory assertions to the contrary,” Plaintiff “has pointed to no record evidence supporting the inference that the abovementioned incident[] of alleged mistreatment occurred ‘because of’ any of [Plaintiff’s] protected characteristics.” Petrisch v. HSBC Bank USA, Inc., No. 07-CV-3303, 2013 WL 1316712, at *13 (E.D.N.Y. Mar. 28, 2013).

Section 2000e-2(a)(1) permits a hostile work environment claim based on harassment tied to perceived sexual orientation.

Goings v. Lopinto · filed 2023-03-30(a)(1)

Taking these allegations as true and construed in a light most favorable to Goings, he has adequately pleaded that the basis of the harassment by Hardy was his perceived sexual orientation.

Section 2000e-2(a)(1) permits a hostile work environment claim based on harassment that is severe or pervasive; it need not be both.

Capaldo v. Remington Hotels · filed 2023-03-30(a)(1)

Contrary to Defendants’ argument, a plaintiff need not adduce evidence that the conduct was both “severe and pervasive; instead, a plaintiff need only demonstrate that the conduct was ‘severe or pervasive.’”

Section 2000e-2(a) requires a race-based hostile work environment plaintiff to prove unwelcome harassment based on race, conduct severe or pervasive enough to alter employment conditions, and a basis for employer liability.

Ross v. The University of Chicago · filed 2023-03-31(a)

To state a claim for a hostile work environment based on race under Title VII or Section 1981, therefore, Ross must prove that (1) he was subject to unwelcome harassment; (2) the harassment was based on his race; (3) the harassment was so severe or pervasive as to alter the conditions of employment and create a hostile or abusive working environment; and (4) there is a basis for employer liability.

Section 2000e-2(a)(1) prohibits race-based harassment severe enough to change the terms and conditions of employment.

Crudup v. City of Omaha · filed 2023-03-31(a)(1)

Looking at the totality of the incidents, the Court concludes they are extreme enough to amount to a change in the terms and conditions of Crudup’s employment.

Section 2000e-2(a)(1) covers sex-based hostile work environment claims when harassment is sufficiently severe or pervasive to alter employment conditions.

Yeaman v. City of Burley · filed 2023-04-10(a)(1)

The next question is whether a reasonable jury could find Hodge’s conduct so severe or pervasive as to create a hostile work environment. The Court concludes that it could. Title VII of the Civil Rights Act prohibits employment discrimination based on certain characteristics, including sex. 42 U.S.C. § 2000e–2(a)(1). One form of actionable discrimination is the creation of a hostile work environment.

A single racial epithet used by coworkers does not establish a hostile work environment under § 2000e-2(a)(1) without a sufficiently aggravating factor.

Moss v. Saja Restaurant Group, LLC · filed 2023-04-21(a)(1)

Without some sufficiently aggravating factor, this single instance in which a racial epithet was used by coworkers does not rise to the level of being severe or pervasive.

Section 2000e-2(a)(1) permits a hostile work environment claim when discrimination based on a protected characteristic is sufficiently severe or pervasive to alter employment terms or conditions.

Ayoade v. Johnson County Community College · filed 2023-04-21(a)(1)

Plaintiff has failed to show a genuine issue of fact with respect to the second element of a hostile work environment claim; Defendants are accordingly entitled to summary judgment on that facet of Plaintiff’s Title VII and ADEA claims.

Section 2000e-2(a)(1) permits a hostile work environment claim when sexual harassment is severe or pervasive enough to alter employment conditions and the employer may be liable for it.

COLAVECCHIA v. SOUTH SIDE AREA SCHOOL DISTRICT · filed 2023-04-21(a)(1)

This provision prohibits sexual harassment that is “sufficiently severe or pervasive to alter the conditions of [the plaintiff’s] employment and create an abusive working environment,” which may give rise to a hostile work environment claim. ... Accordingly, South Side’s Motion to Dismiss the hostile work environment claim under Title VII will be DENIED.

Section 2000e-2 supports a hostile work environment claim when unwelcome conduct based on sex is severe or pervasive enough to alter employment conditions and is attributable to the employer.

Tully v. Cassaday & Company, Inc. · filed 2023-04-27

To establish a prima facie hostile work environment claim, a plaintiff must show “(1) unwelcome conduct; (2) based on the ... plaintiff’s sex; (3) sufficiently severe or pervasive to alter [her] conditions of employment and create an abusive work environment; and (4) that is imputable to the employer.” Roberts v. Glenn Indus. Grp., Inc., 998 F.3d 111, 117 (4th Cir. 2021). ... Applying these standards, we have reviewed the record and find no reversible error.

Section 2000e-2(a)(1) requires evidence that alleged hostile workplace conduct occurred because of the employee’s sex.

Claflin v. McDonough · filed 2023-05-02(a)(1)

Claflin’s only argument on this point is that she was criticized by her supervisors during the waitlist crisis and that this criticism caused stress and anxiety, but the record lacks evidence that this criticism occurred “because of” Claflin’s age or gender. 29 U.S.C. § 623(a)(1); 42 U.S.C. § 2000e-2(a)(1).

A single sufficiently serious incident of sexual harassment can support a hostile work environment claim under § 2000e-2.

Beran v. VSL North Platte Court LLC · filed 2023-05-17(a)(1)

In particular, the evidence that Eugene shoved Beran against a wall and groped her breasts was a single incident of sufficient seriousness to submit the case to the jury.

Section 2000e-2(a)(1) permits a hostile work environment claim based on recurring sexual rumors that a jury could find altered an employee’s working conditions.

Longhorn v. Oregon Department of Corrections · filed 2023-05-23(a)(1)

Considering the totality of the circumstances, there is sufficient evidence for a jury to find that the sexual harassment Plaintiff experienced was severe and pervasive enough to alter the conditions of her employment and create a hostile work environment.

Section 2000e-2(a) requires racial or sexual harassment to be severe or pervasive enough to alter employment conditions for a hostile work environment claim.

Xu v. Lightsmyth Technologies, Inc. · filed 2023-05-25(a)

In any event, none of these incidents were so ‘severe or pervasive’ as to alter the conditions of Plaintiff’s employment.

Section 2000e-2(a)(1) allows related incidents to be considered together as part of a hostile work environment claim.

Anchante v. Wilkie · filed 2023-05-30(a)(1)

Plaintiff has made clear that she is not bringing these claims as discrete actionable acts but rather as in support of her overall harassment claims. Thus, the Court will consider the incidents as such.

Section 2000e-2(a)(1) prohibits race-based hostile work environments; facially race-neutral comments without evidence of racial animus do not establish one.

LOWERY v. DEJOY · filed 2023-06-02(a)(1)

The comments themselves are facially race-neutral and Mr. Lowery has not designated evidence from which a jury could reasonably infer that the comments were based on racial animus or had anything whatsoever to do with race.

Section 2000e-2(a)(1) requires a hostile work environment plaintiff to show that the harassment occurred because of sex.

Dasilva, Jr. v. Esper · filed 2023-06-02(a)(1)

The Court finds that the Government is entitled to summary judgment on this claim because Dasilva has not created a genuine factual dispute that Potter’s alleged harassment was based on sex.

Section 2000e-2(a)(1) allows a hostile work environment claim based on pervasive, sexually derogatory music played throughout a workplace.

Sharp v. S&S Activewear, L.L.C. · filed 2023-06-07(a)(1)

Collectively, then, precedent from our own circuit and other courts of appeals guides us to recognize “sexually graphic, violently misogynistic” music as one form of harassment that can pollute a workplace and give rise to a Title VII claim.

Section 2000e-2 requires a racial hostile work environment to be because of the employee’s race.

Allen v. Yellen · filed 2023-06-09(a)(1)

In other words, as the Title VII statute puts it, the hostile environment must have been “because of” Plaintiff’s race.

Section 2000e-2(a)(1) supports distinct disparate treatment and hostile work environment claims that are analyzed separately.

Kennedy v. Austin · filed 2023-06-09(a)(1)

As set forth in detail above, disparate treatment and hostile work environment are distinct theories of discrimination and, thus, are analyzed separately, even though they both arise under Section 2000e-2(a)(1).

Section 2000e-2(a)(1) permits a sex discrimination claim based on a hostile work environment when a jury could find sufficiently severe harassment and employer liability.

Pianko v. General R.V. Center, Inc. · filed 2023-06-09(a)(1)

For the reasons that follow, the Court, viewing the facts in the light most favorable to Pianko, finds that a reasonable jury could decide that Pianko has met these disputed requirements and thus that she has established a hostile work environment claim.

Section 2000e-2(a)(1) supports a hostile work environment claim when alleged sex-based harassment is severe or pervasive, harms the employee, and gives rise to employer liability.

ZUCAL v. COUNTY OF LEHIGH · filed 2023-06-14(a)(1)

In sum, based upon these factual allegations Palmer has plead sufficient factual allegations to state a Title VII Hostile Work Environment claim against Gieringer and Bailey.

Section 2000e-2(a)(1) prohibits racially hostile work environments, but an isolated race-based remark by a coworker does not meet the severe-or-pervasive requirement.

Robinson v. Priority Automotive Huntersville, Inc. · filed 2023-06-15(a)(1)

So the isolated instance of Cornelius—Plaintiffs’ peer—allegedly saying, “come over to the white side” to another employee does not constitute “severe or pervasive” racial harassment.

Section 2000e-2(a)(1) prohibits sex-based conduct that creates a hostile work environment by altering the conditions of employment.

Gritz v. Garland · filed 2023-06-21(a)(1)

Title VII of the Civil Rights Act of 1964 makes it “an unlawful employment practice for an employer . . . [to] discriminate against any individual with respect to his compensation, 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)(1). ... At this early stage, Gritz has pled enough factual allegations to sustain a claim that Defendant’s conduct altered the conditions of her employment.

Section 2000e-2(a)(1) requires a racial hostile work environment claim to show race-based conduct sufficiently severe or pervasive to alter employment conditions.

Gleave-Perez v. Neurobehavioral Center for Growth · filed 2023-06-28(a)(1)

Plaintiff has not sufficiently demonstrated evidence, subjective or objective, from which a rational jury could find that she was subjected to unwelcome conduct based on her race or that her workplace was permeated with discriminatory intimidation, ridicule, and insult that was sufficiently severe or pervasive to alter her conditions of employment.

Section 2000e-2(a)(1) requires a hostile work environment to be linked to a protected characteristic and sufficiently severe or pervasive to alter employment conditions.

Montgomery v. McDonough · filed 2023-06-29(a)(1)

A single use of the word “ghetto” by Ms. Horton, who is herself African-American, may be distasteful but does not create a hostile work environment.

A hostile work environment claim under § 2000e-2(a)(1) requires harassment severe or pervasive enough to alter employment conditions.

U.S. Equal Employment Opportunity Commission v. Key Management Partners, Inc. · filed 2023-07-05(a)(1)

Accordingly, because Pedro’s conduct was not so severe and pervasive to alter McKenzie’s employment conditions, the Court cannot grant default judgment on the harassment claim.

A hostile work environment requires conduct sufficiently severe or pervasive to alter employment conditions; a few isolated, less serious incidents over two years do not suffice.

Copeland v. Graybar Electric Company Inc · filed 2023-07-10(a)(1)

The conduct outlined above does not meet this threshold.

Section 2000e-2(a)(1) allows a hostile work environment claim to proceed when an alleged sexual assault is sufficiently severe.

SPARKS v. SPEEDY KLEENE CAR WASH & LAUDROMAT · filed 2023-07-13(a)(1)

The Court therefore finds that the alleged assault makes the harassment severe enough to allow her claim to move forward.

Section 2000e-2(a)(1) covers hostile work environment claims based on race or national origin when the harassment meets the required standard.

Davis Long v. State of Illinois Department of Human Services · filed 2023-08-05(a)(1)

Considering these factors, the Court finds that Davis has demonstrated a genuine issue of fact for trial with respect to her claim that she suffered a hostile work environment based on her race but not on the basis of her national origin.

Section 2000e-2(a)(1) covers same-sex harassment that creates a sufficiently severe or pervasive hostile work environment.

Castillo v. Comfort Tech Plumbing, Inc. · filed 2023-08-14(a)(1)

Here, Plaintiff and his alleged harasser, Larry Blank, are both men, but that is no obstacle to proving discrimination on the basis of sex. ... Thus, Plaintiff’s harassment claim is substantively meritorious on the pleadings.

Section 2000e-2(a)(1) requires alleged hostile-work-environment harassment to be connected to the employee’s sex; allegations involving sexual conduct alone do not suffice.

Chesley v. Mesquite · filed 2023-08-14(a)(1)

Chesley’s claim of sexual harassment predicated on a hostile work environment fails because he does not offer any argument that links the alleged harassment he experienced with his male sex; Chesley nowhere argues that his sex was a but-for cause of the alleged harassment.

Section 2000e-2(a)(1) requires harassment to be severe or pervasive enough to alter employment conditions; an employer may also avoid liability when an employee unreasonably delays using its procedures for reporting harassment.

Dickerson v. Koch Foods, LLC · filed 2023-08-21(a)(1)

Dickerson did not present evidence of severe or pervasive harassment sufficient to meet her burden of proof at trial, and in any event, the defendants presented unrebutted evidence that Dickerson was aware of her employer’s procedures for reporting sexual harassment but failed to make use of them until long after the alleged harassment had ceased.

A racially hostile work environment claim requires harassment severe or pervasive enough to alter the conditions of employment.

Young v. Fed Ex Express · filed 2023-08-29(a)(1)

Young has not met the fourth element because he has not alleged sufficient facts to show the harassment was sufficiently “severe or pervasive.”

Section 2000e-2(a)(1) requires a hostile work environment plaintiff to allege harassment severe or pervasive enough to alter the conditions of employment.

GOOLSBY v. CITY OF MONROE · filed 2023-09-01(a)(1)

Goolsby’s allegations, accepted as true, fail to allege harassment that was sufficiently severe or pervasive to alter the terms and conditions of employment and create a discriminatorily abusive working environment.

Section 2000e-2(a)(1) requires severe or pervasive conduct to support a hostile work environment claim.

Allen v. Ford Motor Company · filed 2023-09-08(a)(1)

Though Allen had concerns with the language used amongst employees as well as physical contact such as hugging in the workplace, this does not amount to severe or pervasive conduct.

A Title VII hostile work environment claim requires evidence that the harassment was based on protected status.

Clark v. City of Alexandria · filed 2023-09-13(a)(1)

Mr. Clark’s allegations are insufficient to comprise a hostile work environment claim as a matter of law. This is true for three reasons. First, most of Clark’s allegations do not bear any relationship to race, and there is otherwise no evidence indicating that the complained-of conduct was racially motivated.

An employer is not liable for coworker harassment under § 2000e-2(a)(1) when it promptly remedies the harassment after an employee complains.

Chillmon v. Village of Evergreen Park Illinois · filed 2023-09-14(a)(1)

But while these comments may have risen to the level of a hostile work environment, Evergreen Park cannot be held liable for them because it quickly rectified the issue in response to Chillmon’s complaints.

Section 2000e-2(a)(1) prohibits sex-based hostile work environments; a claim requires harassment based on sex that is severe or pervasive.

Johnson v. Ross Township Board of Trustees · filed 2023-09-15(a)(1)

Because Johnson fails to make a prima facie case of hostile work environment, the Court GRANTS summary judgment in Defendants’ favor on Counts 1 and 2.

Section 2000e-2(a)(1) permits a race-based hostile work environment claim when the alleged conduct amounts to an abusive working environment.

Harris v. Wilkie · filed 2023-09-18(a)(1)

Plaintiff’s allegations do not amount to an abusive working environment.

Section 2000e-2 prohibits a racially hostile work environment when race-based conduct is severe or pervasive enough to alter an employee’s working conditions.

Mingo v. The City of Mooresville · filed 2023-09-18(a)(1)

In summary, the Court finds that, when viewing all the evidence in the light most favorable to Plaintiff, including all reasonable inferences, Plaintiff has met his burden of proffering sufficient evidence to avoid summary judgment on his claim that he was subject to a racially hostile work environment in violation of Title VII.

Section 2000e-2(a)(1) requires a hostile work environment claimant to allege severe or pervasive discrimination based on a protected characteristic.

HOOKS v. RDS AUTOMOTIVE GROUP MASERATI OF THE MAINLINE · filed 2023-09-26(a)(1)

Even considering the totality of the circumstances, the Court cannot reasonably infer from Hooks’ allegations that she has satisfied the “severe or pervasive” standard required to allege a Title VII claim based on a hostile work environment.

Section 2000e-2(a)(1) requires harassment to affect a term, condition, or privilege of employment to support a hostile work environment claim.

Husak v. Baylor Scott & White Health · filed 2023-09-28(a)(1)

Thus, for the reasons discussed above, the Court concludes that, as pled, Husak has failed to show the fourth element of a hostile work environment claim—that the harassment affected a term, condition, or privilege of employment.

Section 2000e-2(a)(1) requires conduct counted toward a hostile work environment claim to be caused by prohibited discrimination.

Harris v. The Public Health Trust of Miami-Dade County · filed 2023-10-04(a)(1)

We agree with Public Health Trust that three of the inci- dents weren’t caused by Harris’s race and, accordingly, shouldn’t be considered as part of the hostile-work-environment calculus.

Section 2000e-2(a)(1) prohibits racial harassment when it is sufficiently severe or pervasive to alter the conditions of employment.

Yelling v. St. Vincent's Health System · filed 2023-10-05(a)(1)

But even if we agreed with Yelling that they were race-based harassment, the comments still would not—alone or with everything else Yelling offers—be sufficient to show a hostile work environment.

A Title VII hostile work environment complaint need only describe who committed the harassment, what happened, and where; exhaustive detail is unnecessary at the pleading stage.

Brown v. Ferrara Candy Company · filed 2023-10-05(a)(1)

Brown need only describe the “who,” “what,” and “where” of the harassment he suffered to prevent dismissal—exhaustive detail is not required.

A jury may find a sexually hostile work environment when an employee experiences multiple physically threatening incidents and verbal harassment over three full-time shifts.

Beran v. VSL North Platte Court LLC · filed 2023-10-18

Unlike the situation in either Watson or LeGrand, Beran was subjected to concentrated harassment over three full-time shifts—not incidents scattered over ten days or nine months. The incidents Beran suffered also involved multiple incidents of physically threatening conduct—not just a single incident of sexual touching or a single grabbing of the buttocks—as well as other verbal harassment. The harassment she suffered was sufficiently different in scale and effect on her working environment from the conduct at issue in Watson and LeGrand for a reasonable jury to find in her favor.

Section 2000e-2(a)(1) prohibits race-based hostile work environments when harassment is sufficiently severe or pervasive to alter the conditions of employment.

Morris v. Department of Veterans Affairs · filed 2023-10-23(a)(1)

Under Title VII of the Civil Rights Act of 1964, an employer may not discriminate against an employee “with respect to [her] compensation, terms, conditions, or privileges of employment, because of such individual's race....” 42 U.S.C. § 2000e–2(a)(1). The creation of a hostile work environment is one way in which an employer can practice discrimination. ... The Court finds that these incidents, viewed individually or as a whole, were not sufficiently severe or pervasive to create a hostile work environment.

Section 2000e-2(a)(1) requires a basis for holding the employer responsible for an alleged racially hostile work environment.

BILITY v. UNIVERSITY OF PITTSBURGH · filed 2023-10-25(a)(1)

As Mr. Bility did not plead sufficient facts to show that respondeat superior liability existed concerning his Hostile Work Environment claim, the University’s Motion to Dismiss will be granted.

A racially threatening noose display can be severe enough to establish an objectively hostile work environment under Section 2000e-2(a)(1).

Achee v. Incorporated Village of Valley Stream · filed 2023-10-30(a)(1)

Under Banks, Mr. Caracciolo’s statement that his white coworkers would assist in hanging Mr. Achee, combined with his showing Mr. Achee an image of a noose is, on its own, sufficiently severe to cause a reasonable person to consider the Valley Stream Parks Department a hostile work environment.

Section 2000e-2(a) covers sex-based harassment severe enough to create an abusive work environment.

Alatorre v. Ole Mexican Foods Inc · filed 2023-11-06(a)

Here, Alatorre has pled facts sufficient to state a claim for hostile work environment based on sex. Perez made sexual comments about Alatorre’s appearance, kissed Alatorre without her consent, and attempted to touch Alatorre sexually to the point that Alatorre had to push Perez off. These allegations support an inference that Perez’s actions were motivated by sexual desire. They are also severe enough to demonstrate that the environment would subjectively and objectively be considered abusive.

Section 2000e-2(a) requires a hostile work environment claimant to allege membership in a protected class.

AYERS v. INFINITY DENTAL MANAGEMENT LLC · filed 2023-11-08(a)

Again, because Ayers does not allege he is a member of a protected class, any hostile workplace claim cannot proceed.

Section 2000e-2 requires a hostile work environment to be severe or pervasive enough to alter the conditions of employment.

Sousa v. Amazon.com Inc · filed 2023-11-13

Sousa’s hostile work environment claim fails because she has not sufficiently alleged that Dorsey’s conduct was so severe or pervasive that it altered her conditions of employment.

Section 2000e-2(a)(1) requires race-based harassment to be severe or pervasive enough to alter the conditions of employment for a hostile work environment claim.

Stanley v. Mount Sinai Health System, Inc. · filed 2023-12-01(a)(1)

Such episodic comments, however, do not rise to the level of being objectively “severe or pervasive,” which is necessary to establish a prima facie case of a hostile work environment under Title VII and Section 1981.

Section 2000e-2(a)(1) requires allegations of sufficiently severe or pervasive harassment to state a hostile work environment claim.

Baker v. Lala Branded Products, LLC. · filed 2023-12-04(a)(1)

Plaintiff’s vague allegations regarding racial harassment and his allegations of sexual harassment, even when construed liberally, fail to suggest the kind of severe and pervasive conduct required to support a hostile environment claim.

Section 2000e-2 requires a hostile work environment claim to plausibly connect the alleged harassment to a protected characteristic.

SCOTT v. ANTIC · filed 2023-12-05(a)(1)

Ms. Scott has alleged facts consistent with both possibilities but has not alleged facts specifically connecting the camera incident to motivations to harass her on the basis of sex. At this juncture, Ms. Scott has not plausibly alleged that Defendants perpetuated a hostile work environment and that they were motivated by Ms. Scott's protected status under Title VII.

Section 2000e-2(a)(1) permits a hostile work environment claim based on alleged sexual assaults to proceed when disputed facts prevent summary judgment on the employer’s harassment defense.

Sherman-Harris-Golson v. Forest Park Police Department · filed 2023-12-15(a)(1)

Golson’s Title VII hostile work environment claim must proceed to trial.

Section 2000e-2(a)(1) does not make workplace harassment actionable when it stems from personal dislike rather than a protected trait.

Ouderkirk v. Rescue Mission Alliance of Syracuse · filed 2023-12-19(a)(1)

Thus, given that Plaintiff testified that Defendant’s employees harassed her out of personal dislike (which is not a protected classification under Title VII), her claims fail as a matter of law.

Section 2000e-2(a)(1) permits a sex-based hostile work environment claim to proceed when the evidence raises a genuine dispute over whether discriminatory conduct was severe or pervasive enough to alter employment conditions.

Edwards-Yu v. Dejoy · filed 2023-12-20(a)(1)

The district court erred in granting summary judgment in favor of USPS with respect to Edwards-Yu’s Title VII and ADEA hostile work environment claims..

Section 2000e-2(a)(1) requires evidence that race- or sex-based harassment was severe or pervasive enough to affect a term, condition, or privilege of employment.

Lewis v. Eye Care Surgery Center, Inc. · filed 2023-12-22(a)(1)

Considering all evidence presented in the light most favorable to the Plaintiff, the Court finds that Plaintiff has failed to establish a prima facie case of hostile work environment based on race or sex because she has failed to present competent summary judgment evidence to substantiate her claims, and she has similarly failed to demonstrate that the alleged conduct was so severe or pervasive that it affected a term, condition, or privilege of her employment.

Section 2000e-2(a)(1) requires national origin harassment to be severe or pervasive enough to alter the terms and conditions of employment for a hostile work environment claim.

Mukhina v. Walmart Inc. · filed 2024-01-03(a)(1)

In sum, considering the facts in a light most favorable to Plaintiff, the record fails to establish that Plaintiff was subjected to severe or pervasive harassment based on her national origin which altered the terms and conditions of her employment.

Section 2000e-2(a) permits an employer to be held liable for a discriminatory hostile work environment when the employer knew or should have known of employee harassment and failed to act.

Nakanwagi v. Executive Office of the Trial Court · filed 2024-01-03(a)

Because the allegations support a plausible inference that defendant knew or should have known of misconduct by its employees and purportedly failed to act on that knowledge to protect plaintiff, the complaint sufficiently states a claim for a hostile work environment.

Section 2000e-2(a)(1) permits a race-based hostile work environment claim based on pervasive workplace harassment without a separate adverse employment action.

De Piero v. PENNSYLVANIA STATE UNIVERSITY · filed 2024-01-11(a)(1)

For the reasons set forth above, Defendants’ Motion to Dismiss will be denied with respect to his hostile work environment theory of liability pressed under Title VII, Section 1981, and the PHRA.

Section 2000e-2(a)(1) permits a racially hostile work environment claim against an employer that knew or should have known about coworker harassment and failed to take corrective action.

Dean v. Wal-Mart Stores, Inc. · filed 2024-01-22(a)(1)

Accordingly, the Complaint makes plausible that Walmart knew or should have known that Kent was creating a racially hostile work environment and failed to take any corrective action.

Section 2000e-2(a) prohibits employment discrimination based on protected traits; a hostile work environment claim requires mistreatment tied to a protected trait.

Thompson v. Illinois Department of Corrections · filed 2024-01-25(a)

Here, Plaintiff has failed to allege that he has been the subject of some form of adverse employment action or that any adverse employment action was taken because of an aggrieved employee’s membership in a protected class.

Section 2000e-2(a) permits a hostile work environment claim when racial harassment is sufficiently severe or pervasive to alter employment conditions.

Montgomery v. Prisma Health · filed 2024-02-05(a)

The court recognizes that while the magistrate judge referred to the “sufficiently severe and pervasive standard” (ECF No. 13 at 5) (emphasis added), which seems to indicate a conjunctive requirement, the correct standard is in the disjunctive – requiring either sufficient severity or sufficient pervasiveness.

A single incident of sexual harassment may establish a hostile work environment if it is sufficiently severe.

King v. Baxter County, Arkansas · filed 2024-02-12(a)(1)

Even a single incident of harassment, if sufficiently severe, may be actionable.

A gender-based hostile work environment claim requires conduct sufficiently severe or pervasive to alter the conditions of employment; a single comment outside the relevant period does not suffice.

Aoun v. City of Las Vegas · filed 2024-02-12(a)(1)

This single comment is not sufficiently severe or pervasive enough to alter the conditions of Plaintiff’s employment and was made before the relevant time period in this litigation.

Section 2000e-2(a)(1) requires sex-based harassment to be severe or pervasive enough to create a hostile work environment.

Roesinger v. Pohanka of Salisbury, Inc. · filed 2024-02-21(a)(1)

Because the totality of the evidence fails to create a genuine question of material fact about whether Roesinger endured sex-based harassment so severe or pervasive that it constituted a hostile work environment, we affirm summary judgment for Pohanka on this claim as well.

Section 2000e-2(a)(1) requires a hostile work environment plaintiff to establish both objective and subjective elements.

Moll v. Telesector · filed 2024-02-28(a)(1)

To prove a hostile work environment in violation of Title VII, a plaintiff must establish both objective and subjective elements.

Section 2000e-2(a)(1) allows a hostile work environment claim to reach a jury when persistent misgendering, inappropriate comments, and a distinct dress code could be found severe and pervasive enough to harm the employee and a reasonable person.

CUNNINGHAM v. BURLINGTON COAT FACTORY WAREHOUSE CORPORATION · filed 2024-02-29(a)(1)

Because the Court finds that a reasonable jury could find that the treatment toward Plaintiff was severe and pervasive enough to detrimentally affect her and a reasonable person, summary judgment will be denied.

Section 2000e-2(a) requires a hostile work environment claim to allege objectively hostile or abusive conditions caused by a protected characteristic.

Perez v. City of New York · filed 2024-02-29(a)

Plaintiffs allege that Defendants subjected them to a hostile work environment, in violation of Title VII, 42 U.S.C. § 2000e-2(a), because of their Hispanic national origin. But the complaint fails to plead such a claim.

Section 2000e-2(a)(1) requires a link between workplace harassment and an employee’s protected characteristic for a hostile work environment claim.

Browne v. State of New York · filed 2024-03-04(a)(1)

The episodic, isolated, and unpleasant exchanges Plaintiffs had with their co-workers, cannot be the basis of a hostile work environment claim because there is no evidence of a link between the alleged hostile conduct and Plaintiffs’ membership in a protected class.

A Title VII hostile work environment claim requires evidence that the alleged harassment occurred because of a protected characteristic.

Daniels v. Board of Education for Anne Arundel County Public Schools · filed 2024-03-08(a)(1)

Here, Plaintiff has not generated sufficient evidence to demonstrate that he was harassed or otherwise discriminated against because of his age or race.

A hostile work environment claim under § 2000e-2(a)(1) requires plausible allegations of harassment severe or pervasive enough to alter employment conditions; a single training session without harassment in daily work did not meet that standard.

Young v. Colorado Department of Corrections · filed 2024-03-11(a)(1)

In short, Mr. Young has not plausibly alleged severe or pervasive harassment that altered the terms or conditions of his employment to create an abusive work environment.

Section 2000e-2(a)(1) covers a hostile work environment created by sexual harassment when the alleged conduct could reasonably be found hostile or abusive.

Randall v. United Parcel Service Incorporated · filed 2024-03-12(a)(1)

Given the facts alleged, a reasonable person could find Plaintiff’s employer, management, and co-workers’ conduct was hostile or abusive.

Section 2000e-2(a)(1) requires a sex-based hostile work environment claim to plausibly connect the alleged harassment to the employee’s sex.

Gress v. DeJoy · filed 2024-03-12(a)(1)

In asserting these factual allegations, Plaintiff does not reference the sex, or the protected class to which he belongs, let alone establish a sufficient connection between his sex and the conduct alleged.

Section 2000e-2(a)(1) prohibits race-based workplace harassment that is severe or pervasive enough to alter the conditions of employment.

Jordan v. Downtown Development District · filed 2024-03-19(a)(1)

But even assuming Jordan can prove he was racially harassed by Davis, no genuine issue of material fact exists as to whether such harassment was sufficiently severe or pervasive or pervasive to implicate Title VII.

Section 2000e-2(a)(1) allows facially race-neutral harassment to count toward a race-based hostile-environment claim when it is sufficiently connected to overtly racist conduct.

Smith v. United States Postal Service · filed 2024-03-20(a)(1)

A close reading of these cases demonstrates, however, that facially race-neutral conduct can support a race-based hostile-environment claim when the race-neutral conduct is sufficiently connected to overtly racist conduct.

Section 2000e-2(a)(1) requires sexual harassment to be sufficiently severe or pervasive to support a hostile work environment claim.

Cusatis v. Atlantic Waste Services, Inc. · filed 2024-03-25(a)(1)

While Freas’s conduct may have been inappropriate and made Plaintiff uncomfortable, it is simply not sufficient to sustain a claim under Title VII.

Section 2000e-2 covers sex-based harassment that is sufficiently severe or pervasive to alter an employee’s working conditions and is attributable to the employer.

Portillo v. H Restaurant and Night Club, LLC · filed 2024-03-25(a)(1)

On this record, where servers could not go to work without risking sexual assault, the unwelcome conduct was sufficiently severe and pervasive to alter the conditions of the work environment.

Section 2000e-2(a)(1) requires facts plausibly showing a hostile work environment based on religion to support a religious harassment claim.

Wehrly v. Allstate Ins. Co. · filed 2024-03-27(a)(1)

Even if he had not waived the issue, based on our review of the record and taking the facts in the light most favorable to Wehrly, we agree with the district court that Wehrly failed to plead facts that plausibly establish a hostile work environment based on his religion.

Section 2000e-2(a)(1) permits a hostile work environment claim when harassment based on a protected characteristic is severe or pervasive enough to alter the terms or conditions of employment.

Copeland v. Georgia Department of Corrections · filed 2024-03-28(a)(1)

At last, guided by our discussion of the four factors, we consider whether, under the totality of the circumstances, a reasonable jury could conclude that the harassment Copeland faced was objectively severe or pervasive enough to alter the terms or conditions of his employment. See Mendoza, 195 F.3d at 1246. We are more than satisfied that it could.

Section 2000e-2(a)(1) prohibits religious harassment that creates an objectively and subjectively hostile work environment.

Buck-Yael v. Washington University · filed 2024-03-28(a)(1)

The Court finds that the facts as alleged at this early stage are sufficient to state a cause of action for a hostile work environment based on Plaintiff’s religion, both as it would be viewed objectively by a reasonable person and as it was actually viewed subjectively by Plaintiff, especially considering the revocation of her religious accommodations.

Section 2000e-2(a) permits a sex-based hostile work environment claim when alleged conduct plausibly creates an objectively hostile workplace that the employee subjectively perceives as hostile.

Brown v. Fat Dough Incorp. · filed 2024-03-29(a)

The Amended Complaint alleges facts allow a plausible inference that Defendant created a working environment that was objectively hostile or abusive because of Plaintiff’s sex and that Plaintiff subjectively perceived it as such. ... Accordingly, Defendant’s motion to dismiss is denied as to Plaintiff’s sex-based hostile work environment claim.

Section 2000e-2(a)(1) does not impose hostile work environment liability for an isolated racial insult that is neither pervasive nor sufficiently severe.

Stuczynski v. The Scotts Company LLC · filed 2024-03-30(a)(1)

As such, no reasonable factfinder could conclude Beamon’s single statement was sufficiently severe or pervasive to constitute a hostile work environment.

Section 2000e-2(a) prohibits sex-based harassment that is severe or pervasive enough to create a hostile work environment.

Gaudette v. Angel Heart Hospice, LLC · filed 2024-04-10(a)

These facts do not rise to level of a hostile work environment. ... An “isolated” incident cannot qualify as pervasive or frequent harassment. ... The comments also cannot be considered “severe.”

Section 2000e-2(m) requires evidence that sex was a motivating factor in the alleged discrimination; sex-neutral conduct alone does not establish that motive.

Overfield v. State of Kansas · filed 2024-04-15(m)

To show discrimination because of sex, a plaintiff need only put forth evidence that sex was a “motivating factor.” 42 U.S.C. § 2000e-2(m).

Section 2000e-2(a)(1) allows a race-based hostile work environment claim to reach a jury when the evidence supports severe or pervasive harassment and a basis for employer liability.

YOUNGER v. THE GEORGE SCHOOL · filed 2024-04-17(a)(1)

Again, viewing the record evidence in the light most favorable to Younger, I find it may reasonably be inferred that he suffered intentional, severe and/or pervasive harassment based on his race, which detrimentally affected him as it would any other reasonable person in similar circumstances, and that a basis for employer liability exists given the George School took no actions to address Gersie’s behavior.

Section 2000e-2(a)(1) requires a hostile work environment claim to allege harassment based on a protected trait that is severe or pervasive enough to alter employment conditions.

Henderson v. Tower Federal Credit Union · filed 2024-04-22(a)(1)

Plaintiff fails to allege facts sufficient to support the second and third elements of a hostile work environment claim.

Section 2000e-2(a)(1) requires a hostile work environment claim to allege harassment based on race, color, religion, sex, or national origin.

Pitts v. Waffle House · filed 2024-05-01(a)(1)

Likewise, to state a Title VII hostile work environment claim, Plaintiff was required to allege, inter alia, that the complained-of harassment was based on his race, color, religion, sex, or national origin. ... Plaintiff’s complaint does not allege that any actions by Waffle House or its employees had to do with his or anyone else’s race, color, religion, sex, or national origin. He has failed to state retaliation and hostile work environment claims under Title VII.

Section 2000e-2(a) covers hostile work environment claims, which require harassment based on membership in a protected class.

Carpenter v. Westin Hotel · filed 2024-05-02(a)

A hostile work environment claim is a type of discrimination claim under 42 U.S.C. § 2000e-2(a). ... The Court therefore concludes that Plaintiff has failed to state a valid Title VII discrimination claim against Westin Hotel.

Section 2000e-2(a)(1) requires severe or pervasive discriminatory conduct to establish a racially hostile work environment.

CARTER v. PSEG SERVICES CORPORATION · filed 2024-05-03(a)(1)

Here, Plaintiff has not demonstrated that the remarks made by co-workers Fennimore and Cassel and the materials displayed in the employee locker room constitute “severe or pervasive” conduct as that phrase is defined.

Section 2000e-2 requires a race-based hostile work environment plaintiff to show offensive harassment based on protected class membership that is severe or pervasive and attributable to the employer.

Stribling v. United Parcel Service Inc · filed 2024-05-03

To prove a hostile work environment claim, a plaintiff must show: “(1) the work environment was both subjectively and objectively offensive; (2) the harassment was based on membership in a protected class; (3) the conduct was severe or pervasive; and (4) there is a basis for employer liability.”

Section 2000e-2(a) prohibits race-based harassment that is severe or pervasive enough to alter the conditions of employment.

REYES v. MCDONOUGH · filed 2024-05-17(a)

Mr. Reyes has not designated evidence showing that the conduct of Sgts. Duchene and Hawley, whether considered alone or collectively, created a hostile work environment based on race.

Title VII hostile work environment harassment must be sufficiently severe or pervasive; simple teasing, offhand comments, and isolated incidents generally do not suffice.

Ibeh v. Secretary Department of Navy · filed 2024-05-28(a)

Even if the state- ments were admissible, the district court did not err in finding that Ibeh failed to show that the comments were severe and pervasive because the statements consisted of simple teasing, offhand com- ments, or isolated incidents.

A hostile work environment claim under § 2000e-2(a)(1) must plausibly allege conduct based on sex that was severe or pervasive.

Skinski v. Planar Systems, Inc. · filed 2024-06-11(a)(1)

And as to the latter theory, Plaintiff has neither alleged that the unwelcome conduct she was subjected to was because of her sex nor alleged that the conduct was sufficiently severe or pervasive.

Section 2000e-2(a) permits a sexual harassment claim when the employer knew or should have known of a hostile work environment and failed to take effective action to stop it.

Yampierre v. Baltimore Police Department · filed 2024-06-17(a)

There accordingly exists a genuine dispute of material fact regarding whether Defendant had actual notice of Plaintiff’s sexual harassment concerns and failed to act properly in addressing those concerns.

Section 2000e-2(a) supports a racial hostile work environment claim when the plaintiff plausibly alleges race-based harassment severe or pervasive enough to alter employment conditions.

Taliaferro v. HCA · filed 2024-06-25(a)

Although Plaintiff’s allegations are somewhat cursory, they suggest “an adequate factual basis” for colorable Title VII hostile work environment and retaliation claims.

Section 2000e-2(a)(1) requires hostile work environment harassment to be based on a protected status and sufficiently severe or pervasive to alter employment conditions.

Herrington v. Target Corporation · filed 2024-06-28(a)(1)

Neither incident constitutes actionable harassment.

A race-based hostile-work-environment claim requires evidence linking the alleged harassment to race; speculation alone is insufficient.

Cromity v. City of Orlando · filed 2024-07-08(a)(1)

But none of McCrimmon’s comments, as described by Cromity, address or even refer to Cromity’s race.

Section 2000e-2(a)(1) permits a sex discrimination claim based on a hostile work environment when the harassment can be imputed to the employer.

Payne v. Jet Blue Airways Corporation · filed 2024-07-09(a)(1)

The Court agrees that Plaintiff abandoned any claims based on a disparate theory of discrimination but holds that summary judgment is inappropriate as to Plaintiff’s hostile work environment theory of discrimination under Title VII.

Section 2000e-2(a)(1) requires evidence that alleged harassment was based on national origin to establish a hostile work environment claim.

Alusi v. Frisco, Texas, City of · filed 2024-07-10(a)(1)

Alusi has failed to show that he faced harassment based on his national origin such that he can establish a hostile work environment claim.

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.

HARRIS v. SALLIE MAE BANK · filed 2024-07-15(a)(1)

Mr. Harris's allegations simply do not rise to the level of the severe and pervasive conduct required for a discrimination claim based on a hostile work environment.

Section 2000e-2(a)(1) requires courts evaluating a hostile work environment claim to consider relevant harassment outside the physical workplace.

Okonowsky v. Garland · filed 2024-07-25(a)(1)

For another, we have held that conduct that took place outside of the physical work environment is part of the totality of the circumstances we evaluate when considering a hostile work environment claim.

Section 2000e-2(a)(1) requires facts showing that workplace harassment was tied to a protected class and created an abusive environment.

Shortey v. Kansas City Shippers Association · filed 2024-07-25(a)(1)

Shortey’s complaint fails to establish any of the required elements for a hostile work environment claim.

Section 2000e-2(a)(1) allows a hostile work environment claim based on mistreatment that is not itself an adverse employment action if it is severe or pervasive enough to alter the terms, conditions, or privileges of employment.

Harper v. Vilsack · filed 2024-07-26(a)(1)

Certainly, a hostile work environment claim may exist “even if the mistreatment does not rise to the level of a tangible employment action[,]” so long as “the mistreatment is sufficiently severe or pervasive that it can be said to alter the terms, conditions, or privileges of employment.”

Section 2000e-2(a)(1) requires sex-based discrimination for a hostile work environment claim; sexualized conduct alone does not suffice.

Workman v. LHC Group, Inc. · filed 2024-07-29(a)(1)

These requirements are fatal to any plausible Title VII claim based on the nonspecific conduct alleged in Workman’s amended complaint.

Section 2000e-2(a)(1) requires evidence of severe or pervasive discriminatory conduct to support a hostile work environment claim.

HOLLINGSWORTH v. RABE ENVIRONMENTAL SYSTEMS, INC. · filed 2024-07-30(a)(1)

Based on this record, the Court finds that no reasonable jury could conclude that any discriminatory conduct occurred that was severe or pervasive enough to create a hostile work environment, and summary judgment will be granted in favor of Defendant accordingly.

Section 2000e-2(a)(1) permits a race-based hostile work environment claim when the alleged harassment is objectively severe or pervasive.

Gates v. Oklahoma Health and Wellness Center · filed 2024-08-05(a)(1)

Taking Plaintiff’s allegations as true, Plaintiff has adequately pled that Defendant’s conduct, “considering all the circumstances,” was objectively severe and pervasive.

A Title VII hostile work environment claim requires hostility because of the employee’s membership in a protected class.

Ramos v. Hartford · filed 2024-08-09(a)(1)

To establish a hostile work environment claim, “[a] plaintiff must . . . demonstrate that []he was subjected to the hostility because of h[is] membership in a protected class.” Brennan v. Metro. Opera Ass’n, Inc., 192 F.3d 310, 318 (2d Cir. 1999).

A hostile work environment claim under § 2000e-2(a)(1) requires harassment based on sex that is sufficiently severe or pervasive to alter the conditions of employment.

Barrett v. Team Industrial Services, Inc · filed 2024-08-20(a)(1)

Higgins’s actions, even when viewed together, do not amount to a hostile work environment.

A Title VII hostile work environment claim must plausibly link the alleged harassment to a protected trait; harassment arising from a request for a religious exemption can support that inference.

Obermeyer v. Department of Veterans Affairs · filed 2024-08-21(a)(1)

Obermeyer has met this standard only as to religion. She alleged that all of Dr. Koenigsknecht’s questions and harassment arose from the fact that she requested a religious exemption from the COVID-19 vaccine and testing. That is sufficient at the pleading stage to raise an inference that the harassment was based on her religious belief.

Pornographic images in the workplace may support a hostile work environment claim based on sex without allegations of gender-specific epithets.

Stone v. Truist Bank · filed 2024-08-23(a)(1)

Nowhere did the Fourth Circuit indicate that pornography without gender- specific epithets would fail to meet the “because of sex” requirement.

Section 2000e-2(a)(1) requires conduct supporting a hostile work environment claim to be connected to the employee’s protected class.

Young v. Perdue · filed 2024-08-26(a)(1)

None of the events Plaintiff cites had any discernable connection to his membership in a protected class, such that no reasonable jury could find he was subjected to a hostile work environment based on his race or sexual orientation.

Section 2000e-2(a)(1) permits a hostile work environment claim to consider discriminatory harassment directed at others when assessing the workplace as a whole.

Navarro v. Stratford · filed 2024-08-30(a)(1)

In a hostile work environment claim, “‘the crucial inquiry focuses on the nature of the workplace environment as a whole,’ and ‘a plaintiff who [himself] experiences discriminatory harassment need not be the target of other instances of hostility in order for those incidents to support [his] claim.’” Kaytor, 609 F.3d at 546 (citations omitted).

Section 2000e-2(a)(1) requires conduct to be severe or pervasive enough to alter working conditions for a hostile work environment claim.

WALTER v. MCDONAUGH · filed 2024-09-03(a)(1)

Thus, one conversation regarding Plaintiff’s dress is not severe or pervasive enough to establish a hostile work environment.

Section 2000e-2(a)(1) covers race-based workplace harassment that is sufficiently severe or pervasive to alter the conditions of employment.

Mais v. Albemarle County School Board · filed 2024-09-09(a)(1)

Here, Mais has adduced evidence which would allow a reasonable jury to conclude that the unwelcome conduct she experienced was sufficiently severe or pervasive.

A plaintiff cannot establish supervisor-based vicarious liability for a hostile work environment without evidence that the harasser was the plaintiff’s supervisor.

Hamilton v. The Federal Savings Bank · filed 2024-09-10(a)(1)

Assuming—solely for purposes of argument—that a reasonable jury could find that Floropoulos’s allegedly racist and homophobic comments were “sufficiently severe or pervasive” as “to alter the conditions of [Hamilton’s] employment and create an abusive working environment,” the record evidence would not permit it to find that Floropoulos was Hamilton’s supervisor.

Section 2000e-2(a)(1) prohibits sex discrimination in employment, including sexual harassment that creates a hostile work environment.

Rivera v. The CSI Companies Inc · filed 2024-09-23(a)(1)

As a general matter, Title VII prohibits an employer from discriminating against an individual “with respect to [her] compensation, terms, conditions, or privileges of employment” because of the individual’s sex. 42 U.S.C. § 2000e-2(a)(1). This prohibition encompasses various forms of sexual harassment, including discrete acts of discrimination and a hostile work environment claim. ... Accordingly, Ms. Rivera may proceed with a sexually hostile work environment claim under Counts I and III.

Section 2000e-2(a) does not treat employer emails encouraging vaccination, without more, as a religiously hostile work environment.

Zerveskes v. Mass General Brigham Incorporated · filed 2024-09-26(a)

And, as the defendants argue and Zerveskes concedes in her objection, an employer’s emails encouraging its employees to get vaccinated do not support a religious discrimination claim based on a hostile work environment.

Section 2000e-2(a)(1) requires race-based harassment to be sufficiently severe or pervasive to create an abusive work environment.

Decoster v. Becerra · filed 2024-10-02(a)(1)

We find that Decoster’s allegations fall short of being severe or pervasive enough to show an abusive environment. Therefore, Decoster has not stated a plausible hostile work environment claim.

A coworker’s single comment about sexual orientation does not establish a hostile work environment when it is not severe or pervasive, and the employer was unaware of it.

Wilson v. Lear Corporation · filed 2024-10-02(a)(1)

Ms. Hawkins’ single comment about sexual orientation isn’t enough to establish a hostile work environment. Though again inappropriate, the comment was not part of sexual orientation harassment so severe or pervasive as to be actionable, and Lear cannot be liable when it wasn’t aware of the comment about Ms. Wilson’s protected class status.

Section 2000e-2(a)(1) supports a hostile work environment claim when harassment based on color or national origin is severe or pervasive enough to alter employment conditions.

Moussa v. Advent Health South Overland Park, Inc. · filed 2024-10-04(a)(1)

Plaintiff can establish her claim of a hostile work environment based on unlawful color or national origin discrimination by showing (1) she was harassed because of her national origin or color, and (2) that the harassment was sufficiently severe or pervasive such that it altered the terms or conditions of her employment.

Section 2000e-2(a)(1) requires a racially hostile work environment to be objectively severe or pervasive; ordinary workplace slights do not suffice.

Hunter v. Carl Buddig And Company · filed 2024-10-05(a)(1)

Here, Hunter fails to allege facts hinting at a work environment that was objectively offense and severe or pervasive under the Gates factors.

Section 2000e-2(a) prohibits race- or sex-based workplace harassment that is sufficiently severe or pervasive to alter the conditions of employment.

Gauna v. Frisella Nursery, Inc. · filed 2024-10-07(a)

The Court therefore concludes that Plaintiff has failed to satisfy the high threshold for a hostile work environment claim based on either racial or sexual harassment, and that she has failed to raise a genuine issue for trial.

Section 2000e-2(a)(1) requires a racial hostile work environment claim to involve conduct based on race that is severe or pervasive enough to alter employment conditions.

Andrews v. DeJoy · filed 2024-10-08(a)(1)

Andrews does not satisfy the second and third elements of a hostile work environment.

An employer is strictly liable for a supervisor’s hostile work environment harassment that culminates in a tangible employment action and cannot assert an affirmative defense.

Russell v. United States Department of the Army · filed 2024-11-07(a)(1)

One, an employer is subject to strict vicarious liability “when the supervisor’s harassment culminates in a tangible employment action, such as discharge, demotion, or undesirable reassignment[.]” Id. (quotation cleaned up). Because an employer in this first scenario is strictly liable, it can’t assert an affirmative defense.

Section 2000e-2(a)(1) makes workplace harassment actionable when it is sufficiently severe or pervasive to alter employment conditions.

Waller v. Jet Specialty, Inc. · filed 2024-11-19(a)(1)

These instances are not sufficiently severe or pervasive to be actionable under Title VII.

Section 2000e-2(a)(1) requires evidence that alleged workplace harassment was based on sex.

Detillion v. Ohio Dep't of Rehab. & Corr. · filed 2024-11-21(a)(1)

Detillion’s alleged harassment is actionable under Title VII only if she presents evidence that it grew from “discriminatory animus against women.” Schlosser v. VRHabilis, LLC, 113 F.4th 674, 684–85 (6th Cir. 2024). She has not done so.

Section 2000e-2(a)(2) requires a religious hostile work environment claim to allege harassment because of religion; harassment directed at unvaccinated workers alone is insufficient.

French v. St. Charles Health System, Inc. · filed 2024-12-06(a)(2)

As summarized above, Plaintiffs French, Leonard, and Jackson allege conduct directed at unvaccinated individuals, but there are no allegations which would allow a plausible inference that the conduct occurred “because of” their protected religious status.

Section 2000e-2(a)(2) requires a hostile work environment claim to allege harassment because of a protected trait such as religion; harassment based only on vaccination status is insufficient.

Kruskopf v. St. Charles Health System, Inc. · filed 2024-12-06(a)(2)

Here, Plaintiffs did not plausibly allege that they experienced harassment because of their religious status. As summarized above, Plaintiffs Kruskopf, Schmidt, and Noble alleged conduct directed at unvaccinated individuals, but there are no allegations which would allow a plausible inference that the conduct occurred “because of” their protected religious status.