The remarks included a comment by the senior living community’s executive director that a third-party employee was an “ignorant black bitch.”

Affirming summary judgment against the Title VII race discrimination claim of a Black sales and marketing director for a senior living community, the D.C. Circuit found that several alleged statements by management, including referring to a third-party worker as an “ignorant black bitch” and calling a group of African-American men “monkeys,” were not direct evidence of race-based discrimination and the employee failed to show her termination for insubordination and unprofessional conduct was pretextual. The court also affirmed summary judgment on the employee’s retaliation claim as well as her hostile work environment claim, but on the alternate ground that it was untimely. In addition, the court affirmed the dismissal of her public policy wrongful termination and tortious interference with business relations claims. Judge Wilkins, in a separate concurring opinion, argued that the district court’s hostile work environment analysis “was irreconcilable with Meritor’s endorsement of the Fifth Circuit’s opinion in Rogers” (Latture v. Priority Life Care, LLC, No. 25-7063 (D.C. Cir. Sept. 8, 2026)).

Hired in January 2021 as the sales and marketing director by the family-run business that manages senior living communities throughout the United States, the employee was charged with preparing a new facility for its grand opening in the...

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