In Rhone v. Marco A. Rubio, No. CV 24-3389 (RC), 2025 WL 3017791 (D.D.C. Oct. 28, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964.
From the decision:
To plead a hostile work environment claim, the plaintiff must allege facts showing “that [her] employer subjected [her] to discriminatory intimidation, ridicule, and insult that is sufficiently severe or pervasive to alter the conditions of the victim’s employment and create an abusive working environment.” Baloch, 550 F.3d at 1201 (citation modified). To assess the existence of a hostile work environment, “the court looks to the totality of the circumstances, including the frequency of the discriminatory conduct, its severity, its offensiveness, and whether it interferes with an employee’s work performance.” Id. For a work environment to be considered hostile, the offensive conduct must “permeate[ ] the workplace.” Stewart v. Evans, 275 F.3d 1126, 1133 (D.C. Cir. 2002) (citation modified).
Here, Plaintiff’s allegations regarding her increased workload, denials of requests for assistance, and unpleasant interactions with her supervisors do not rise to the requisite level of severity or pervasiveness to constitute a hostile work environment. To start, Plaintiff has alleged the “same discrete acts” on which her discrimination and retaliation claims are premised to support her hostile working environment claim, which is “disfavor[ed].” Doe, 2024 WL 864270, at *7 (quoting Townsend, 236 F. Supp. 3d at 312). Although “incidents of disparate treatment can establish a hostile work environment,” such incidents must be “connected in a pervasive pattern of severe harassment.” Id. (emphasis added) (quoting Wade v. District of Columbia, 780 F. Supp. 2d 1, 19 (D.D.C. 2011)). Even construing Plaintiff’s complaint liberally, there is no sign that Plaintiff’s alleged employer misconduct is connected in this manner. As discussed above, Plaintiff has not plausibly connected her allegations, besides her discrete forced-resignation and non-selection claims, to her race or her protected activities, which might have indicated such a pattern. See id. (holding that the plaintiff’s alleged “pattern of specific incidents of disparate treatment and retaliation” that were linked to her race and national origin constituted a hostile work environment). Instead, Plaintiff’s allegations describe “the ‘ordinary tribulations of the workplace’ reflecting an employee’s difficult relationship with a supervisor,” which are insufficient to support a hostile work environment claim. Sledge v. D.C., 63 F. Supp. 3d 1, 26 (D.D.C. 2014) (quoting Faragher v. City of Boca Raton, 524 U.S. 775, 788 (1998)).
Thus, the court held that dismissal was warranted.