Woods v. Cantrell
United States Court of Appeals for the Fifth Circuit
29 F.4th 284 (2022)
- Written by Jamie Milne, JD
Facts
Anthony Woods (plaintiff) sued his former employer, French Market Corporation (defendant), asserting multiple claims, including a hostile-work-environment claim under Title VII of the Civil Rights Act of 1964 (Title VII). Most of the claims in Woods’s complaint were conclusory, failing to include any specific supporting facts. However, in support of the hostile-work-environment claim, the complaint alleged that Woods’s Hispanic supervisor, in front of other employees, called Woods, a Black man, a “Lazy Monkey A__ N____.” In a lengthy opinion, the district court addressed and dismissed Woods’s conclusory claims and his hostile-work-environment claim. Regarding the hostile-work-environment claim, the district court held that the single utterance of a racial slur, no matter how despicable, was insufficient to create a hostile work environment. Woods filed a pro se appeal to challenge the dismissal of his claims.
Rule of Law
Issue
Holding and Reasoning (Jolly, J.)
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