On April 1, 2011, the Fourth Circuit issued an interesting and thorough decision in a hostile work environment case from North Carolina. The Fourth Circuit held that the district court improperly granted summary judgment on the hostile work environment claim, while affirming the dismissal of the remaining claims. There is useful language in this decision on the impropriety of summary judgment in hostile work environment cases, and a key paragraph follows:
"On appeal, Freightliner pursues a similar approach and undertakes to defend the district court’s summary judgment on the issue of severity/pervasiveness by cataloging some of the myriad cases that have come before this court and that involved behavior considerably more offensive and opprobrious than that shown here. While this tack is understandable, and assuming that other cases involve more heinous behavior in male dominated workplaces than that shown here, we have never held that a weak case is necessarily one that should be disposed of on summary judgment. The question at the summary judgment stage is not whether a jury is sure to find a verdict for the plaintiff; the question is whether a reasonable jury could rationally so find. Spillman, 925 F.2d at 95. On this record, we are satisfied that the answer to that query is "yes" and that it was error for the district court to rule to the contrary as a matter of law. We have never held that a grant of summary judgment in favor of a defendant is a legitimate substitute for a jury verdict in favor of a defendant, and we decline to do so here."
Hoyle v. Freightliner, LLC, No. 09-2024 (4th Cir. Apr. 4, 2011)
The decision is online at: http://pacer.ca4.uscourts.gov/dailyopinions/opinion.pdf/092024.P.pdf
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