Employment-D.C. Circuit Rules That Unprofessional And Uncivil Behavoir Does Not Establish A Case Of Racial Or Sexual Discrimination In Violation Of Title VII

In Brooks v. Grundmann, No. 12-5171 (D.C. Cir. 2014), the plaintiff, Patricia Brooks (“Brooks”), was appealing the district court’s summary judgment in favor of her employer. The D.C. Circuit Court of Appeals (the “Court”) reviewed the record. It noted that Brooks claims her supervisors at work engendered a hostile work environment, discriminating against her on the basis of her race and sex. The Court concluded, however, that, while the supervisors’ actions may have been unprofessional, uncivil, and somewhat boorish, they did not constitute an adequate factual basis for the Title VII claims presented. Accordingly, the Court affirmed the district court’s grant of summary judgment.