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Single racial epithet can establish
a hostile work environment claim

Woods v. Cantrell (5th Cir 03/24/2022)
Sent to Custom Alerts™ subscribers on 03/27/2022

Anthony Woods filed suit against his former employer, alleging that he was subjected to a hostile work environment in violation of Title VII.

He claimed that in the presence of other employees, his supervisor, a person of Hispanic descent, directly called him a "Lazy Monkey A__ N____."

The district court dismissed Woods’s hostile work environment claim because "a single utterance of a racial epithet, despicable as it is, cannot support a hostile work environment claim."

The 5th Circuit reversed in a 3 1/2 page opinion.

The 5th Circuit held that Woods's court complaint states an actionable claim of hostile work environment.

The court said, "As other circuits have recognized, '[p]erhaps no single act can more quickly 'alter the conditions of employment and create an abusive working environment than the use of an unambiguously racial epithet such as [the N-word] by a supervisor in the presence of his subordinates.'"

The court also said, "Furthermore, if supported with adequate proof, Woods could be entitled to emotional and other damages that have been alleged."

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