One Use of N-Word Not Enough for Harassment

A black replacement janitor for a Michigan elementary school failed to support his Title VII hostile environment claim with evidence of one incident in which a co-worker allegedly called him a “black nigger,” the Seventh Circuit ruled June 19 (Nichols v. Mich. City Plant Planning Dep’t, 2014 BL 171106, 7th Cir., 13-2893, 6/19/14).

Affirming summary judgment for the Michigan City Plant Planning Department, the U.S. Court of Appeals for the Seventh Circuit found that one utterance of the N-word is not severe enough to amount to actionable racial harassment under Title VII.

Although James Nichols further alleged that ...