2 Racist Slurs Not Enough For Hostile Work Claim: 4th Circ.

Law360, New York (May 14, 2014, 9:53 PM EDT) -- In a published decision issued Tuesday, the Fourth Circuit found that an employee’s use of a racially derogatory term over the course of two days does not constitute a hostile work environment, ruling against an African-American woman who said she was fired for complaining about the alleged comments.

A three-judge appeals panel ruled that plaintiff Reya C. Boyer-Liberto was not subjected a racially discriminatory work environment at the hotel where she worked after a white co-worker named Trudy Clubb allegedly called her a “porch monkey” on two occasions.

“The ‘porch monkey’ term that Clubb used was indeed racially derogatory and highly...

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