In Turner v. Copeland Group USA Inc, 2022 WL 1508446 (S.D.Tex. May 10, 2022), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s race-based hostile work environment claim asserted under Title VII of the Civil Rights Act of 1964.
The court summarized the relevant facts as follows:
Plaintiffs Vanessa La Barrie and Celmira Turner are former sales and marketing directors at Copeland’s Houston office. La Barrie worked there from February 2020 to October 2020. Turner worked there from October 2020 to November 2020.
Plaintiffs allege La Barrie was the only African American sales and marketing director at Copeland during her tenure. Copeland allegedly refused to provide her a team of agents and refused to allow her to work remotely. Yet other similarly situated individuals outside her protected class—namely Brandy Wallace, Denise Reid, and Kim Ayala—allegedly received some or all of these privileges. La Barrie was ultimately terminated in October 2020 and replaced by Turner.
Similarly, Plaintiffs allege that Turner was the only African American sales and marketing director at Copeland during her tenure. Dusty Singleton was Turner’s immediate supervisor and is alleged to have openly mocked Turner and consistently made “subtle remarks” about her “race and stereotypes.” At some point, Turner discussed these comments with Heather Mayfield, an individual in Copeland’s human resources department. Singleton also allegedly moved Turner from the directors office to the front office, a substantially less desirable location. And Plaintiffs contend that similarly situated individuals outside Turner’s protected class—namely Kim Ayala, Denise Reid, Elsa Isais, Alejandre Ruiz, and Dwayne Gueno—received more favorable treatment. Copeland ultimately terminated Turner in November 2020, replacing her with an individual outside her protected class.
[Cleaned up.]
The court held that these allegations, while “scant,” were enough to satisfy plaintiff’s low pleading threshold.