Espinal v. Nat'l Grid NE Holdings 2, LLC , No. 11-1682 (1st Cir. 2012)Annotate this Case
Plaintiff appealed from entry of summary judgment against his claims of race-based disparate treatment and of hostile work environment against Employer. Plaintiff's complaint alleged Employer punished him more harshly for a rules violation, on the basis of his Hispanic heritage, than it did a similarly situated white co-worker and permitted other employees to harass him in violation of Title VII. The First Circuit Court of Appeals affirmed, holding that summary judgment was appropriate on both of Plaintiff's claims, as (1) Employer's reasons for disciplining Plaintiff, on the record, did not allow inferences or pretext or discrimination, and there was no differential treatment; and (2) Employer took reasonable steps to address the alleged co-worker harassment.