In Reed v. Remington Arms Co., Inc., No. 25-2886, 2026 WL 3024473 (8th Cir. Oct. 8, 2026), the court, inter alia, affirmed the lower court’s grant of summary judgment in favor of defendant on plaintiff’s race and sex-based hostile work environment claims asserted under Title VII of the Civil Rights Act of 1964.
From the decision:
The district court found that Reed failed to establish that any of the alleged harassment she endured was sufficiently hostile or abusive to support a claim of a hostile work environment. And it also concluded that Reed failed to provide any evidence linking her alleged mistreatment to her race or sex. The district court is correct.
First, Reed’s evidence of a hostile work environment primarily consisted of her co-workers turning off her machines before her shift began, incorrectly reporting in the company logbook that Reed had not worked her shift, blaming her for machine failures, and throwing away her slug guide. Our precedent requires far more hostile and abusive circumstances. See, e.g., Ways v. City of Lincoln, 871 F.2d 750, 755 (8th Cir. 1989) (evidence included approximately fifty examples of racial harassment); Stone v. McGraw Hill Fin., Inc., 856 F.3d 1168, 1175 (8th Cir. 2017) (finding no triable hostile work environment claim where plaintiff presented evidence his superior “grabbed his arm during a meeting,” co-workers “interfered with [his] working relationships with his colleagues,” he was not accepted as part of his superior’s team, and he was “subjected … to unduly harsh work requirements”).
Reichel, Reed’s coworker, testified that he heard a racial expletive and saw racist t-shirts in the workplace. But this testimony does not change the calculus. Although Reed argues that Reichel’s testimony supports the existence of an objectively hostile work environment, Reed must still show that the hostile work environment was subjectively hostile. See Carter v. Atrium Hosp., 997 F.3d 803, 811 (8th Cir. 2021) (emphasizing that both the objective and the subjective standard must be satisfied). In other words, Reed is required to show she was subject to harassment, and the harassment affected her employment and working conditions. See Williams v. ConAgra Poultry Co., 378 F.3d 790, 794 (8th Cir. 2004) (“Because a subjectively hostile environment is one that by definition the plaintiff is aware of, a plaintiff cannot recover for harassment of which he or she is unaware.”). Reichel’s experience is irrelevant to Reed’s subjective experience. But even if Reed had these same experiences and subjectively perceived severe and pervasive harassment, “our cases require that a plaintiff show more than … a few occurrences over a course of years” to establish an objectively hostile work environment. See Singletary, 423 F.3d at 893 (several uses of racial epithets were not frequent enough to establish a hostile work environment); see also Burkett v. Glickman, 327 F.3d 658, 662 (8th Cir. 2003) (“[O]ffhand comments and isolated incidents of offensive conduct (unless extremely serious) do not constitute a hostile work environment.”). Therefore, the district court rightly determined that Reed could not show the conditions necessary to support her claim.
Second, even if Reed could establish a hostile work environment, the district court correctly found she did not provide any evidence her mistreatment was linked to her race or sex. Yekel offered non-discriminatory reasons for most of the allegedly hostile behavior, indicating that the machines were shut off as standard practice and for safety reasons and that the slug guide was likely thrown away by accident. Reed did not present any contradictory evidence which would create a genuine dispute of material fact on these issues.
The court concluded by noting that plaintiff “failed to present evidence connecting the alleged harassment to her protected status or indicating her harassment was so severe or pervasive as to alter her conditions of employment” and, thus, the district court correctly granted summary judgment.