Court of Appeals for Fourth Circuit reverses Maryland court on hostile work environment claim
In its opinion published March 31, 2008, the United States Fourth Circuit Court of Appeals in EEOC v. Sunbelt Rentals found that an employee had established a basic claim for hostile work environment based upon religious discrimination. The Court found that a "genuine dispute of fact with respect to each element of [the] hostile work environment claim" filed by EEOC on behalf of Clinton Ingram, an employee of Sunbelt Rentals. Opinion at p. 19.
Initiating the litigation, the EEOC filed a complaint in the United States District Court for the District of Maryland on behalf of Ingram against Sunbelt Rentals. The EEOC claimed a hostile work environment based upon religion, and violation of Title VII of the Civil Rights Act of 1964 and Title I of the Civil Rights Act of 1991. Sunbelt filed a motion for summary judgment which the Court granted. The trial court "did not believe the harassment was severe or pervasive enough to establish a prima facie case of a hostile work environment." Opinion at p. 7. The EEOC appealed to the Fourth Circuit Court of Appeals which issued this ruling reversing the grant of summary judgment and remanding the case for trial.
