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Co-worker disagreements do not always constitute a hostile work environment
Rhodes Hieronymus successfully defended a restaurant client at the summary judgment stage against claims of race discrimination, hostile work environment and retaliatory discharge under Title VII and 42 U.S.C. §1981 by a former employee. The United States District Court for the Western District of Oklahoma agreed that while plaintiff’s co-workers’ behavior may have been inappropriate, it fell short of the requisite behavior necessary to succeed on a race-based hostile work environment claim. The Court also granted summary judgment on the race discrimination and retaliatory discharge claims, concluding plaintiff failed to demonstrate his race was a factor in his termination, and plaintiff failed to engage in protected activity.
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