The U.S. Court of Appeals for the Tenth Circuit reversed a New Mexico federal district court’s decision and denied summary judgment to Walmart on a hostile work environment claim under Title VII of the Civil Rights Act brought by a gay male employee working various positions, finding sufficient evidence of severe anti-gay harassment, including a supervisor comparing homosexuality to pedophilia and bestiality, regular use of homophobic slurs by coworkers, and a drawing depicting “Faggot” in capital letters, where the district court had erroneously excluded relevant discriminatory acts and applied an incorrect “steady barrage” standard.
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