Parker v. Reema Consulting Services, Inc.

915 F.3d 297 (2019)

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Parker v. Reema Consulting Services, Inc.

United States Court of Appeals for the Fourth Circuit
915 F.3d 297 (2019)

Facts

Evangeline Parker (plaintiff) worked for Reema Consulting Services, Inc. (RCSI) (defendant). In March 2016, she was promoted to assistant operations manager. Donte Jennings started a rumor that Parker was promoted because of a sexual relationship with Demarcus Pickett, a higher-ranking manager. The rumor was false. Jennings had started work at RCSI alongside Parker but was now her subordinate. Larry Moppins, the facility’s highest-ranking manager, helped spread the rumor. Coworkers, including Parker’s supervisees, treated Parker with resentment and disrespect. In April 2016, Moppins called a staff meeting to discuss the rumor. Moppins allowed Pickett to attend but slammed the door in Parker’s face and locked her out. When Moppins later met with Parker, he reprimanded her for bringing the situation to the workplace and told her that the rumor would prevent her from further advancement. At a follow-up meeting, Moppins said he should have terminated Parker for complaining. He then lost his temper and started screaming at her. Parker filed a sexual-harassment complaint against Jennings and Moppins with human resources. A few weeks later, Jennings filed a retaliatory complaint against Parker. Parker was instructed to have no contact with Jennings, but Jennings was allowed to enter Parker’s area and talk to her employees. In May 2016, Moppins fired Parker. Parker sued RCSI, asserting various claims under Title VII of the Civil Rights Act of 1964, including a hostile-work-environment claim based on sex discrimination. The district court dismissed the claim, finding that (1) Parker’s harassment was not based on her sex but on false allegations of conduct and (2) the harassment was not severe or pervasive enough to create a hostile work environment. Parker appealed.

Rule of Law

Issue

Holding and Reasoning (Niemeyer, J.)

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