Robert Collier v. Dallas County Hospital District

Summary

**Title VII Retaliation – Pretext; Hostile Work Environment – Severity/Pervasiveness.** The Fifth Circuit affirmed summary judgment for the employer, holding that the African American plaintiff failed to show that his termination for insubordination was pretextual or that but-for retaliation caused his firing. The court also held that racial graffiti (including the N-word and swastikas) and being called "boy" were not sufficiently severe or pervasive to establish a hostile work environment under Title VII.

Holdings

1. Parkland offered legitimate, nondiscriminatory reasons for Collier's termination (insubordination), and Collier failed to demonstrate that those reasons were pretextual or that his complaints of racial discrimination were a but-for cause of his termination.
2. The conduct complained of (two instances of racial graffiti, being called 'boy') was not sufficiently severe or pervasive to alter the conditions of employment and create an abusive working environment.

Questions Presented

1. Whether the district court erred in granting summary judgment on Collier's retaliation claim (pretext and but-for causation).
2. Whether the district court erred in granting summary judgment on Collier's hostile work environment claim (severity/pervasiveness).

Disposition

affirmed