Title VII hostile environment claims only succeed on egregious, not merely offensive, conduct.

Evidence

Adopting this reasoning, the Seventh Circuit in Cerros v. Steel Technologies Inc. stated “[w]hile there is no ‘magic number’ of slurs that indicate a hostile work environment, we have recognized before that an unambigu- ously racial epithet falls on the ‘more severe’ end of the spectrum.” — Sahar F. Aziz, Sticks and Stones, the Words That Hurt, 222 (#qualifies-own, via linked claim)

Consequently, employers often argue that the alleged conduct is a form of “simple teasing, offhand comments, and isolated incidents” that are not actionable.”’ Moreover, when an employer employs others of the same national origin as the plaintiff, ethnic remarks made during a casual conversation may be used to show a lack of intent necessary to establish national origin discrimina- tion. — Sahar F. Aziz, Sticks and Stones, the Words That Hurt, 223 (#qualifies-own, via linked claim)

Although the plaintiff had not lost sales as a result of the alleged harassment, the Fifth Circuit noted that Title VII’s prohibition “is not limited to ‘economic’ or ‘tangible’ discrimination”. — Sahar F. Aziz, Sticks and Stones, the Words That Hurt, 319 (#builds-on, via linked claim)

Categorization

• XREF: connects to: Employers defeat hostile-environment claims by invoking simple teasing and offhand comments. — Sahar F. Aziz, Sticks and Stones, the Words That Hurt:…, 223; There is no fixed number of slurs required to establish a hostile work environment. — Sahar F. Aziz, Sticks and Stones, the Words That Hurt:…, 222; Title VII hostile environment claims need no lost sales or tangible harm. — Sahar F. Aziz, Sticks and Stones, the Words That Hurt:…, 319

Related

• Employers defeat hostile-environment claims by invoking simple teasing and offhand comments. (similarity 0.89)
• There is no fixed number of slurs required to establish a hostile work environment. (similarity 0.86)
• Title VII hostile environment claims need no lost sales or tangible harm. (similarity 0.81)
• Habitual cumulative epithet use can permit harassment claims to reach trial (similarity 0.78)