In Marquis v. Philadelphia Gas Works, No. 2:25-CV-07005-JDW, 2026 WL 711802 (E.D. Pa. Mar. 13, 2026), the court denied defendant’s motion to dismiss plaintiff’s sex-based hostile work environment claim asserted under Title VII of the Civil Right Act of 1964.
From the decision:
During her time at PGW, Ms. Marquis experienced various workplace incidents that she describes as sexual harassment. On her first day of employment, a male coworker used a gender-based slur, and a manager refused to give her information to contact HR. Then, when PGW fired the co-worker for violence, PGW refused to provide safe transportation for her the next day. She experienced a “hostile ‘mean girl’ environment” when two coworkers engaged in a pervasive culture of isolation and intimidation. In November and December 2025, a coworker engaged in pervasive sexual harassment, including comments on Ms. Marquis’s physical appearance, invasive medical questioning, and violations of physical boundary protocols. That same coworker spoke over her and undermined her. A trainer told her that he liked black hair more than Ms. Marquis’s blonde hair. An Attendance Manager required Ms. Marquis to remove a headband. Ms. Marquis tried to report those incidents, but two people from HR shamed her for not using the label “sexual harassment.” …
To plead a hostile work environment claim under Title VII, a plaintiff must allege: (1) she suffered intentional discrimination because of membership in a protected class; (2) the discrimination was severe or pervasive; (3) the discrimination detrimentally affected her; (4) it would have detrimentally affected a reasonable person in like circumstances; and (5) a basis for employer liability is present. Starnes v. Butler Cnty. Ct. of Common Pleas, 50th Jud. Dist., 971 F.3d 416, 428 (3d Cir. 2020). Ms. Marquis alleges that she suffered regular slights based on her sex throughout many months, and she includes several specific examples. She also alleges that some of the harassment came from supervisors and from HR employees.
The court concluded that “[a]t this early stage of the case, her allegations are enough to state a claim for hostile work environment.”