Although a former trainee for the Drug Enforcement Agency alleged instances of name-calling, profanity and being “ridiculed” and laughed at by her supervisors, and being required to repeat training exercises more than others and to perform training exercises with male counterparts, these allegations were insufficient to support a hostile work environment claim.
Background
Saudhy Bliss, who is female and of Hispanic descent, was a DEA, basic agent trainee, or BAT. After being removed from the training academy and ultimately terminated from the DEA, plaintiff filed suit alleging that her “termination resulted from the discriminatory conduct of” training academy personnel, and that “Defendant has allowed a course of conduct which results in disparate treatment for individuals who are female, brown skin and of Hispanic national origin.”
In her third amended complaint, plaintiff brings two claims pursuant to Title VII of the Civil Rights Act of 1964: (1) a disparate treatment claim on account of plaintiff’s sex, color and national origin (Count One) and (2) a hostile work environment claim on account of plaintiff’s sex, color and national origin (Count Two). Defendant has filed a motion to dismiss.
Intersectionality
Plaintiff asserts claims of disparate treatment and hostile work environment “on the basis of her sex, her color, and her national origin.” The court treats the disparate treatment claim on the bases of sex, color and national origin “in tandem” because plaintiff...
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