In Nicholson v. Michael Rigas, Acting Adm’r, Gen. Servs. Admin., No. 24-2894 (RBW), 2026 WL 686071 (D.D.C. Mar. 11, 2026), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s race-based hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964.
From the decision:
[T]he Court concludes that the plaintiff has failed to adequately establish a hostile work environment claim based on her race because she has failed to show “some linkage between the hostile behavior” and her race. Although the plaintiff claims that her supervisors’ conduct was based on race because they are of a different race than the plaintiff, the Complaint is devoid of any allegations that any of her supervisors commented on or otherwise ever referred to her race. Indeed, the plaintiff alleges only one instance in which she was “questioned … about attending a Blacks in Government monthly meeting during her lunch hour in violation of Agency policy[.]” However, the plaintiff alleges this inquiry related to her attending the meeting during her lunch hour, not that Ms. Ellis’s inquiry resulted from the nature of the meeting itself. (Citations omitted.)
The court concluded that “without more, this single, indirect association with the plaintiff’s race precludes the Court from inferring that the hostile work environment was the result of discrimination based on [the plaintiff’s] protected status.” (Internal quotation marks omitted.)