In Laghari v. State of Connecticut Department of Correction, No. 3:25-CV-1373-(VAB), 2026 WL 1622989 (D. Conn. June 5, 2026), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s hostile work environment claims, based on race and national origin, asserted under Title VII of the Civil Rights Act of 1964.
From the decision:
[Plaintiff] argues that he was subjected to repeated hostile treatment connected to his race and national origin. Id. at 3 (“When Plaintiff would respond to radio transmissions, the party on the other side would frequently state ‘22,’ which is code for ‘repeat.’ ”); id. (“Although an occasional request to repeat would be understandable, the volume of these requests was unreasonable and meant to demean Mr. Laghari based on his accent.”); id. (“Other COs, even those with accents, did not experience anywhere close to the number of ‘22’ requests.”).
Mr. Laghari also relies on allegations that “Plaintiff would often receive calls wherein the other party would hang up as soon as Plaintiff answered,” id., and that he saw graffiti stating “Go back to Corrigan. Corrigan does not want him” and “POS list” followed by “SMOL” or “suck me off Laghari,” id. at 4. He further argues that, “[w]hen viewed in the context of the totality of the circumstances and deciding all inferences in favor of Plaintiff, the graffiti and ‘chicken balls’ note demonstrate the severity of the racially and ethnically based harassment experienced by Mr. Laghari.” Id. at 10
The DOC argues that Mr. Laghari has not plausibly alleged a hostile work environment because “Plaintiff does not specifically assert a hostile work environment claim in his Complaint” and, “[i]n fact, he does not even mention the term ‘hostile,’ but mentions the word ‘harassment’ four times in his Complaint.” Def.’s Mem. at 19.
The DOC further argues that, “[t]o the extent Plaintiff does attempt to state a hostile work environment claim, it is legally insufficient because Plaintiff fails to plausibly allege that the work environment was sufficiently severe and pervasive to alter the conditions of his employment, and that any of the acts alleged in the Complaint were based on any of his protected categories.” Id.
The DOC also argues that Mr. Laghari “fails to identify the perpetrators or allege how frequently this happened or provide any further details whatsoever to establish that these incidents were ‘severe and pervasive’ to constitute a hostile work environment.” Id. at 21. In the DOC’s view, the alleged incidents involving supervisors “only suggest isolated incidents of conduct that does not even appear offensive and at best describe interactions and feedback between Plaintiff and his superiors on work-related matters,” and the bathroom graffiti allegations “do not even establish that these statements were directed to the Plaintiff or that the note left at his desk about chicken was connected to his protected categories or was offensive in any way.” Id. at 21–22.
The Court agrees in part, and disagrees in part.
At this stage, the Court must consider the alleged incidents collectively, rather than isolate each event and ask whether that event alone would establish a hostile work environment. Under Harris, whether an environment is hostile or abusive “can be determined only by looking at all the circumstances,” including “the frequency of the discriminatory conduct,” “its severity,” whether it is “physically threatening or humiliating,” and whether it “unreasonably interferes with an employee’s work performance.” Harris, 510 U.S. at 23.
When viewed together, Mr. Laghari’s allegations plausibly suggest that the alleged conduct was not merely episodic workplace friction, but part of a broader pattern of discriminatory hostility. Mr. Laghari alleges that, after his transfer to YCI, he “continued to experience acts of discrimination, harassment and retaliation,” id. ¶ 10; that radio requests to repeat were made “frequently,” id. ¶ 11; that harassing phone calls were “frequent,” id. ¶ 13; that he was “continuously” assigned undesirable posts with “lifers,” id. ¶ 17; and that the bathroom graffiti “was not removed for several weeks,” id. ¶ 20.The DOC may ultimately be correct that the alleged incidents were isolated, non-discriminatory, or insufficiently severe or pervasive to support liability. But that conclusion would require a more developed factual record. At this stage, Mr. Laghari need not prove that the alleged conduct actually altered the conditions of his employment, he must allege facts making that inference plausible. Vega, 801 F.3d at 87 (“On a motion to dismiss, the question is not whether a plaintiff is likely to prevail, but whether the well-pleaded factual allegations plausibly give rise to an inference of unlawful discrimination.”).
Here, the Complaint alleges repeated radio and phone harassment tied to Mr. Laghari’s accent, derogatory graffiti that could plausibly be read as directed at him, and a delayed or ineffective response after he complained. Compl. ¶ 11 (“This request to repeat was done to demean the plaintiff due to his accent.”); id. ¶ 20 (“Go back to Corrigan. Corrigan does not want him.”); id. ¶ 22 (“The plaintiff sent an email to Warden Sexton (Caucasian female) about what happened, and she replied there would be a meeting called to discuss this, but the meeting never happened.”); id. ¶ 23 (“the plaintiff wrote a letter to DOC commissioner Angel Quiros about the systemic racism at the facility, and he received no meaningful response.”); see also Pl.’s Mem. in Opp’n at 10 (“Frequent radio and telephone harassment; offensive graffiti directed at Mr. Laghari; false accusations of improper job performance; and arbitrary discipline all demonstrate that the harassment experienced by Plaintiff was both severe and pervasive thus fulfilling the first requirements for establishing a hostile work environment claim.”).
The court reached the opposite conclusion, however, as to plaintiff’s hostile work environment theories based on sex or religion, noting that plaintiff “has not identified comparable factual allegations showing that he was subjected to severe or pervasive hostility because of his sex or religion.”