Judge Rules that African-American Saleswoman Claims of Race-Discrimination and Hostile Work Environment Will be Dismissed


Court: United States District Court – Eastern District of Pennsylvania

Date of Opinion: February 4th, 2022

Judge: Gallagher

Overview: An African-American saleswoman filed a race-discimination and hostile work environment claim against her former employer.  The court granted the defendant’s motion to dismiss the case.

Background:  Plaintiff Erica Chandler, an African American woman, was employed by defendant La-Z-Boy in April 2018.  Despite having a sixteen-year old conviction on her record, La-Z-Boy still hired her.  Chandler claims that Caucasian applicants to La-Z-Boy do not go through the same scrutiny as African Americans.

Chandler states that three weeks into her employment, she was called a “colored girl” by her manager, and she reported the incident to her district manager.  Also, over the following year, Chandler claims that she was “harassed, taunted and singled out on a daily basis.” She resigned from her position in May 2019.  Chander claims in her complaint that she experienced discrimination during her entire year of employment with the defendant.  La-Z-Boy has filed a motion to dismiss this case.

La-Z-Boy argues that Chandler’s claims should be dismissed because 1) she did not plead an adverse employment action and 2) the race-based issue she raised is not severe or pervasive.

The court notes that Chandler claims that she was “constructively discharged” in May 2019, but she does not allege any allegations of discrimination so intolerable that a reasonable person would resign under the same circumstances.  The court opines that the only race-related harassment in this case is the “colored girl” comment, which only happened once during her employment with the defendant.  Thus, the court states that her racial discrimination claim fails.

The court then tackles the hostile work environment claim.  The judge states that the primary claim for a hostile work environment is in the “colored girl” comment.  However, while offensive, does not support a claim for a hostile work environment and, thus, this claim fails as well.

Conclusion:  The court granted the defendant’s motion to dismiss, but left the case open by granting Chandler a leave to amend her complaint.

Steven M. Cohen
Law Librarian | + posts

Steven M. Cohen is a law librarian at a midsize law firm in New York City.  He was the creator of Library Stuff, one of the first library blogs, which lasted over 15 years.  He obtained his MLS from Queens College in 2002.  His passions include legal research, reading novels, and rooting on his favorite sports teams.