A Michigan federal district court granted United Wholesale Mortgage’s motion to compel arbitration of a female mortgage underwriter’s claims under Title VII of the Civil Rights Act and Michigan’s Elliott-Larsen Civil Rights Act, finding that the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act didn’t apply because the plaintiff failed to allege a plausible sexual harassment claim based on a broker’s email stating she was “too pretty to be an underwriter,” as this single incident didn’t meet the “severe or pervasive” standard required for a hostile work environment claim.
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