Smith v. Fairview Ridges Hosp., No. 08-1924

Title VII Hostile Work Environment Matter

In Smith v. Fairview Ridges Hosp., No. 08-1924, an action claiming that defendant constructively discharged plaintiff after subjecting her to a hostile work environment and retaliation, in violation of Title VII, the court affirmed summary judgment for defendant where 1) the evidence did not support plaintiff's contention that her workplace was "permeated with discriminatory intimidation, ridicule, and insult, that was sufficiently severe or pervasive to alter" her conditions of employment; and 2) plaintiff produced no evidence that her coworkers were "involved in or accused of the same offense and [were] disciplined in different ways," thus she did not show that she and her coworkers "were similarly situated in all relevant aspects."

As the court wrote:  "Shelia Smith appeals the district court's adverse grant of summary judgment on her discrimination claims against her former employer, Fairview Ridges Hospital ("Fairview"). Smith contends that Fairview constructively discharged her after subjecting her to a hostile work environment and retaliation, in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000e to 2000e-17. We affirm."

Related Resources

• Read the Eighth Circuit's Decision in Smith v. Fairview Ridges Hosp., No. 08-1924