Although an employee alleged a trainer used the n-word to his face, that was insufficient to support a hostile work environment claim. The isolated incident, dreadful as it is, is too remote and too disconnected from his employer.
Background
Plaintiff Lorenzo Harrison, an African American man, brings four counts in this first amended complaint, or FAC, against the United States Department of Defense for discrimination on the basis of race, retaliation, hostile work environment and constructive discharge in violation of Title VII of the Civil Rights Act of 1964. Defendant has filed a motion to dismiss.
Hostile work environment
Plaintiff alleges that, sometime in 2020, a transnational deployment instructor, Robert Eubank, used the n-word to plaintiff’s face. The court notes that the offensive word was used by someone not directly supervising plaintiff, who did not have further interaction with plaintiff and which the slur occurred more than one year before the claims at issue here arose. This isolated incident, dreadful as it is, is too remote and too disconnected from his employer to support a hostile work environment claim here.
To the extent that plaintiff attempts to state a race-based hostile work environment, plaintiff fails to connect any of the actions of the supervisors to his race. Accordingly, with nothing directly connecting plaintiff’s race to any of the conduct that he faced, plaintiff has failed to establish that there was a race-based hostile work...
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