In Brooks v. Chester Valley Golf Club, No. CV 25-761, 2025 WL 3210349 (E.D. Pa. Nov. 17, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s sex- and race-based hostile work environment claims.
From the decision:
The last incident on which Plaintiff relies to support her allegation of a hostile work environment, and the only allegation in the Amended Complaint that even arguably reflects any discriminatory animus, is Poznick’s statement in the February 11, 2024 email that Plaintiff was “rude and disrespectful.” (1st Am. Compl. ¶ 32.) Plaintiff acknowledges that this criticism did not explicitly mention race or sex, but she maintains that it invokes a racial stereotype of an “angry black woman” and thus, supports inferences of racial and sexual animus and a correspondingly-discriminatory hostile work environment. (See Pl.’s Mem at 10.) “District courts in this circuit have recognized the ‘perniciousness’ of the ‘angry Black woman’ trope and have held the invocation of this stereotype may serve as evidence of discriminatory animus, even where the invocation is not explicit.” Johnson v. Sch. Dist. of Philadelphia, Civ. A. No. 23-3430, 2024 WL 1773358, at *6 (E.D. Pa. Apr. 24, 2024) (quoting Curry v. Devereux Found., 541 F. Supp. 3d 555, 561 (E.D. Pa. 2021), and citing Blount v. TD Bank, N.A., Civ. A. No. 20-18805, 2023 WL 4621881, at *13 (D.N.J. July 19, 2023)).
Here, the allegation in the Amended Complaint is that Ponziak stated that Plaintiff was “rude and disrespectful” when dealing with other Club departments and then used that accusation to justify proposed behavior changes for both Plaintiff and her supervisor, who unlike Plaintiff, is not alleged to be black. (1st Am. Compl. ¶ 32.) Even accepting for purposes of the pending Motion that the “rude and disrespectful” comment in this context evokes an “Angry black woman” trope, the allegation of the single, isolated racial comment can only be characterized as a mere offensive utterance. It was neither physically threatening nor objectively humiliating and certainly was not so severe as to sustain a hostile work environment claim on its own. Accordingly, we conclude that the Amended Complaint does not sufficiently allege discrimination that is either severe or pervasive.
Accordingly, the court held that dismissal was warranted.