Mary E. Harris v. The Public Health Trust of Miami-Dade County, No. 21-11016 (11th Cir. 2023)
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Plaintiff, a black nurse who was disciplined and ultimately fired by her employer, Public Health Trust of Miami-Dade County—appealed the district court’s entry of summary judgment on her Title VII and state-law claims alleging (1) employment discrimination, (2) hostile work environment, and (3) retaliation. Harris contends that the district court erred in rejecting all three claims.
The Eleventh Circuit affirmed. The court wrote that Public Health Trust says that several incidents that occurred at Jackson Reeves shouldn’t be considered because they weren’t caused by Plaintiff’s race. The court wrote that it agreed with Public Health Trust that three of the incidents weren’t caused by Harris’s race and, accordingly, shouldn’t be considered as part of the hostile-work-environment calculus. Further, the court reasoned that even considering Plaintiff’s limited evidence in the light most favorable to her, these are not, given the totality of the circumstances, sufficiently severe or pervasive to alter the terms and conditions of her employment and create an abusive working environment.
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