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Fourth Circuit Affirms Summary Judgment for Employer on Hostile Work Environment Claim, Vacates for Employer on Retaliation Claim
April 28, 2020

In this employment case, Stacy Saunders appealed from the district court's award of summary judgment in favor of her former employer, Metropolitan Property Management Inc. Saunders' action against Metropolitan alleged a hostile work environment and retaliation under Title VII of the Civil Rights Act of 1964.

In affirming the district court's award of summary judgment in favor of Metropolitan on the hostile work environment claim, the Fourth Circuit, focusing on whether an employee's conduct is imputable to Metropolitan, found that there were no disputed issues of material fact concerning the investigation Metropolitan conducted, as the investigation into the employee's conduct was reasonably thorough and completed in a timely fashion.

However, after reviewing the record, the Fourth Circuit concluded that there were genuine disputes of material fact with respect to the retaliation claim, mainly whether Saunders would have been fired but for her complaint of sexual harassment. The Fourth Circuit found that there was compelling evidence to support Saunders' argument that the real reason she was fired was because she engaged in the protected activity of filing a complaint of sexual harassment.

The Fourth Circuit therefore vacated in part the district court's award of summary judgment and remanded the retaliation claim for further proceedings.

Saunders v. Metropolitan Property Management, Inc., No. 18-2008 (4th Cir. Mar. 18, 2020).
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