Garmon v. National Railroad Passenger Corp., No. 15-1803 (1st Cir. 2016)Annotate this Case
Plaintiff, an African-American, filed an employment discrimination case against Amtrak, his employer, alleging that his opportunities for overtime were reduced because of his race and that he was subjected to a hostile work environment. The district court granted summary judgment in favor of Amtrak. The First Circuit affirmed, holding (1) Plaintiff failed to meet his initial burden of establishing a prima facie case of disparate treatment discrimination; and (2) even if Plaintiff’s complaints rose to the level of a hostile work environment, Plaintiff failed to demonstrate that he was subjected to any complained-of actions because of his race.