Rickard v. Swedish Match North America, No. 13-3729 (8th Cir. 2014)
Annotate this CasePlaintiff filed suit under the Age Discrimination in Employment Act of 1967 (ADEA), 29 U.S.C. 621 et seq., and Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., against his employer after he retired. The court concluded that plaintiff's age-based hostile work environment claim failed because the supervisor's age-related comments were not so severe as to affect a term, condition, or privilege of his employment; without more than plaintiff's speculation, a reasonable juror could not find the supervisor's actions - although contemptible - amounted to harassment based on sex; plaintiff has not shown sufficient facts to infer a hostile work environment and he cannot prove constructive discharge; and plaintiff has not suffered an adverse employment action and cannot establish a claim for either disparate treatment or retaliation. Accordingly, the court affirmed the district court's grant of summary judgment in favor of the employer.
Court Description: Civil case - Employment discrimination. Plaintiff's supervisor's age-related comments were not so severe as to affect a term, condition or privilege of employment, and plaintiff's age-based hostile work environment claim must fail; plaintiff's evidence that he was subjected to sex-based harassment was insufficient to state a claim; as plaintiff did not show sufficient facts to infer a hostile work environment, his constructive discharge claim must fail.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.