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A Chrysler employee with a checkered record of cooperation with his co-workers could not establish that he suffered a hostile work environment based on his race, religion and national origin, a Michigan federal court decided.
Farid Beydoun started working as a welder for Chrysler in 2000. He advanced to the position of team leader in 2010. Shortly after becoming a team leader, he began having disputes with some of his co-workers. One involved Robert Bedford, whom Beydoun claims cursed at him and threatened him with violence in May 2011.
Then, in January 2012, Beydoun got into an altercation with co-worker Costell McIntosh, who, Beydoun said, used profanity and threatened him. McIntosh denied making a threat and also denied using profanity, because as a Jehovah's Witness, it would have been against his religion. Both men were sent home that day. After an investigation, human resources could not determine which party was being truthful, so both McIntosh and Beydoun were docked three-four hours of pay. However, Beydoun filed a grievance challenging the dock in pay and had his penalty reduced to two hours.
In June, 2013, Beydoun was having lunch with Jill Reed, a supervisor in training, when Beydoun mentioned that he wished his daughter would find a man whom she would respect and obey. When Reed reacted negatively, Beydoun said he was offended by her reaction and complained to management. Subsequently, H.R. generalist Amanda Darr, Beydoun, and Reed met to discuss the issue, and nothing else came of the incident.
In August 2013, Beydoun sued the company on a number of bases, including hostile work environment, though he remained in his job.
Several months later on March 31, 2014, Beydoun was sitting at a picnic table with his head down when his supervisor, Richard Osuwu, approached him and asked if he was “alright.” In response, Beydoun said, “I can't take it anymore” and threw a box of gloves against a fence. He then punched a board. Beydoun was escorted to the medical department and met with labor relations generalist Brittany Flack. He was later terminated for destroying company property.
When his legal complaint reached U.S. district court, the company asked the court to throw the case out at an early stage.
To establish a good initial case of maintaining a hostile work environment, the court said, Beydoun had to show that: (1) he was a member of a protected class, (2) he was subjected to unwelcome verbal or physical conduct related to his membership in that class, (3) the harassment was based on his membership in that class, (4) the harassment had the purpose of creating an intimidating, hostile, or offensive work environment that was severe or pervasive, and (5) the employer knew or should have known about the harassment, but failed to take any action to prevent it.
Applying those criteria to the evidence, the court stated that although Beydoun certainly fell into a protected class, the record was entirely devoid of evidence supporting his claim that he suffered harassment at the hands of Chrysler employees because of his race, religion, or national origin.
He conceded that the Bedford incident had nothing to do with his protected status. In addition, the court pointed out, Beydoun was actually treated more favorably in the outcome of the McIntosh incident by receiving less hours docked from his pay. Except for Jill Reed's isolated comments, Beydoun could not point to any discriminatory motive underlying any of his other workplace disputes. Therefore, only Reed's comments could be considered in Beydoun's hostile work environment claim.
Evaluating the evidentiary value of her comments, the court said that even assuming that her comments were motivated by discriminatory animus, which was a generous interpretation of the incident, one isolated comment did not amount to a hostile work environment that is severe or pervasive.
Beydoun, the court said, had to show that his work environment at Chrysler was “permeated with discriminatory intimidation, ridicule, and insult that is sufficient severe or pervasive to alter the conditions of [his] employment and create an abusive working environment . . . .” In fact, the court pointed out, Beydoun never claimed that his work was affected by the alleged harassment, and even if he did, the record would not support such a claim. Though the Chrysler Stamping Plant might not qualify as utopian, no reasonable person would find the complained of workplace to be overly abusive, the court said, dismissing the hostile work environment claims.
Beydoun v. Chrysler LLC Group, E.D. Mich.,No. 2:13-cv-13343 (Feb. 5, 2015).
Diane Cadrain is an attorney who has been writing about employment law issues for more than 20 years.
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