Campbell v. Hawaii Department of Education, No. 15-15939 (9th Cir. 2018)Annotate this Case
The 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.