Campbell v. Hawaii Department of Education, No. 15-15939 (9th Cir. 2018)
Annotate this CaseThe Ninth Circuit affirmed the district court's grant of summary judgment for defendants in an action alleging employment discrimination claims. The panel held that plaintiff, a teacher, failed to establish a prima facia case of disparate treatment based on her sex and race under Title VII because she did not show that she was subject to an adverse employment action or that similarly situated individuals outside her protected class were treated more favorably; plaintiff's hostile work environment claim failed because the few isolated and relatively mild comments that plaintiff alleged were not sufficient to show a severe and pervasive environment that altered the terms or conditions of her employment; plaintiff's retaliation claim failed because plaintiff did not establish that defendants' asserted rationale for its actions was mere pretext; and plaintiff's Title IX claims for intentional discrimination failed for essentially the same reasons that her Title VII claims failed.
Court Description: Employment Discrimination. The panel affirmed the district court’s grant of summary judgment in favor of the defendants on employment discrimination claims brought by a public high school teacher who was verbally harassed by her students. Affirming the district court’s grant of summary judgment on the teacher’s Title VII claims of disparate treatment based on her sex and race, the panel held that the teacher failed to establish a prima facie case because she did not show that she was subject to an adverse employment action or that similarly situated individuals outside her protected class were treated more favorably. The panel also affirmed the district court’s grant of summary judgment on the teacher’s Title VII hostile work environment claim. The panel held that the defendant public school system could be held liable for students’ harassing conduct only to the extent that it failed reasonably to respond to the conduct or ratified or acquiesced in the conduct. On the teacher’s Title VII retaliation claim, the panel held that she failed to establish that the defendants’ asserted rationale for its actions was mere pretext.
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