Equal Employment Opportunity Commission v. Sunbelt Rentals, Inc.
United States Court of Appeals for the Fourth Circuit
521 F.3d 306 (2008)
- Written by Robert Cane, JD
Facts
Clinton Ingram worked for Sunbelt Rentals, Incorporated (Sunbelt) (defendant) as a rental manager. Ingram, a Muslim-American, began working for Sunbelt in October 2001, one month after the September 11 attacks. Several Sunbelt employees, including Mike Warner, the shop foreman, and Barry Fortna, the lead rental manager, routinely subjected Ingram to demeaning comments and degrading actions. They called Ingram names like “Taliban” and “towel head.” They made fun of his appearance, specifically his kufi and beard. They made references linking Muslims to terrorism and suggested that Ingram himself was a terrorist and disloyal to the United States. Ingram’s time card was often hidden on Fridays when he went to prayer. Ingram was subject to much more abuse than any other employee. Ingram reported the misconduct by his coworkers to his supervisors, but they took no action to stop the harassment. Warner and Fortna, who engaged in the harassment, sometimes served as acting managers. Ingram filed a complaint with the Equal Employment Opportunity Commission (EEOC) (plaintiff). The EEOC brought a Title VII action on behalf of Ingram against Sunbelt. The district court granted summary judgment in favor of Sunbelt, finding that the harassment was not sufficiently severe or pervasive. The EEOC appealed.
Rule of Law
Issue
Holding and Reasoning (Wilkinson, J.)
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