Coworker's racial slur does not create hostile work environment claim

The truth of the adage "an ounce of prevention is worth a pound of cure" was highlighted in a recent decision by the 4th Circuit (whose rulings apply to all Maryland and Virginia employers). In its ruling, the appeals court held an employer wasn't liable for creating a hostile work environment for an African-American employee even though the company didn't fire the coworker who allegedly made a racist and sexist statement.

Facts

Nicole Bazemore worked at Best Buy. One day at work, her white colleague, Anne Creel, aimed a racially and sexually slur-ridden joke at Bazemore in front of others. Bazemore reported the incident to management. After some time, she was told the situation had been addressed. She wasn't told specifically what action was taken, although she knew Creel wasn't fired.

Creel didn't make any racially offensive statements again. Nevertheless, Bazemore was deeply humiliated by the incident and believed it should have been addressed more publicly and with more severity, including firing.

Given her dissatisfaction with the way in which Best Buy handled her situation, Bazemore sued the retailer in federal district court in Maryland, asserting a claim of hostile work environment under Title VII of the Civil Rights Act of 1964. The company asked the court to dismiss her claim, arguing she had failed to sufficiently allege it should be liable for Creel's conduct. The court agreed and dismissed her case.

Appeal