Clay v. Credit Bureau Enterprises, Inc., No. 12-3207 (8th Cir. 2014)
Annotate this CasePlaintiff filed suit against her employer, CBE, under 42 U.S.C. 1981, alleging claims of race discrimination, hostile work environment, retaliation, and constructive discharge. The district court granted summary judgment in favor of CBE. The court concluded that, even considering the otherwise time-barred acts that were similar to the acts that occurred within the limitations period, plaintiff failed to set forth sufficient evidence to survive summary judgment on her hostile work environment claim. The twelve incidents of alleged harassment that occurred after March 1, 2007, as well as the similar acts that occurred before then, taken together are not sufficiently severe or pervasive to show that plaintiff's work environment was objectively offensive. Having affirmed the district court's decision on the hostile work environment claim, the court need not further address plaintiff's constructive discharge claim. Accordingly, the court affirmed the judgment of the district court.
Court Description: Civil case - Employment discrimination. Even considering certain incidents which were time-barred acts on the ground they were similar to acts that occurred within the limitations period, plaintiff failed to set forth sufficient evidence to survive summary judgment on her hostile work environment claim as the harassment she pointed to was not severe or pervasive enough to affect a term, condition or privilege of her employment; where plaintiff conceded her constructive discharge claim rose or fell on the hostile work environment claim, court would not address the constructive discharge claim in light of its ruling on the hostile work environment claim.
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