The D.C. Circuit Court of Appeals recently held a single use of the “N-Word” by a supervisor may create a hostile work environment in Ayissi-Etoh v. Fannie Mae, No. 11-7127 (D.C. Cir. 2013).
Ayissi-Etoh involved an African-American plaintiff, Placide Ayissi-Etoh, alleging his former employer, Fannie Mae, unlawfully discriminated against him in violation of federal anti-discrimination statute 42 U.S.C. § 1981.
The former financial modeling team lead alleged several instances of discrimination in support of his claims. Ayissi-Etoh first pointed to a conversation he had with a supervisor regarding his salary. The plaintiff had recently been promoted along with 11 white co-workers. However, unlike his white peers, Ayissi-Etoh hadn’t received a corresponding pay raise. He inquired as to why this was, and his white supervisor replied “For a young black man smart like you, we are happy to have your expertise; I think I’m already paying you a lot of money.” Ayissi-Etoh also alleged that a different white supervisor yelled “Get out of my office [n-word]” at him during an unrelated heated exchange. The plaintiff responded by filing a discrimination claim with the Equal Employment Opportunity Commission (EEOC), at which point his employer reportedly gave him an ultimatum: drop the complaint or lose your job. Ayissi-Etoh was subsequently fired. Continue reading “Court Holds Single Act Can Constitute Hostile Workplace”
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