Ward v. KaTom Restaurant Supply, Inc.

Summary

The United States District Court for the Eastern District of Tennessee ruled on KaTom Restaurant Supply, Inc.'s motion for summary judgment in Jack Ward's Title VII action alleging transgender discrimination, retaliation, and hostile work environment. The court denied summary judgment on the sex discrimination claim because factual disputes remained regarding discriminatory animus and the role of a decisionmaker in Ward's termination. The court granted summary judgment on the retaliation and hostile work environment claims.

Holdings

1. Summary judgment was denied because genuine disputes existed regarding whether Ward was terminated because of his transgender identity.
2. KaTom was entitled to summary judgment because Ward did not engage in protected activity.
3. KaTom was entitled to summary judgment because the alleged harassment was not objectively severe or pervasive.

Questions Presented

1. Whether genuine disputes of material fact precluded summary judgment on Ward's Title VII sex discrimination claim based on his transgender identity and termination.
2. Whether Ward engaged in protected activity sufficient to support a Title VII retaliation claim when he emailed human resources to clarify the restroom policy.
3. Whether the alleged comments, restroom restriction, and related conduct were sufficiently severe or pervasive to establish a Title VII hostile work environment.

Disposition

other