In Summary Judgment, Federal Court finds Unfounded Claims of Hostile Work Environment, Race Discrimination, and Retaliation in Washington Federal Court

Last month, Judge Barbara J. Rothstein, a United States District Judge for the Western District of Washington, entered summary judgment in favor of longtime Lewis Rice client Graybar Electric Company, Inc. in a race discrimination lawsuit. The plaintiff had alleged claims of hostile work environment, race discrimination, and retaliation under Title VII and the Washington Law Against Discrimination against Graybar. Specifically, Mr. Copeland claimed he faced a racially hostile work environment and that, his supervisors failed to remediate. Mr. Copeland also claimed that his employment with Graybar was later terminated on grounds of race discrimination and as retaliation for going over his supervisors’ heads to complain to upper management regarding the alleged hostile work environment.

After thorough discovery requests, interrogatories, and third-party subpoenas, as well as 13 depositions taken by the parties in this case, Lewis Rice elicited evidence that Mr. Copeland’s claim of a hostile work environment boiled down to several isolated issues with one co-worker that were not racially motivated. Lewis Rice further demonstrated that Mr. Copeland’s termination was based on his history of workplace disruptions with multiple coworkers that preceded his complaint to upper management and escalated in the following days, culminating in verbally abusive encounters with two different coworkers. 

After the completion of discovery, Lewis Rice filed a motion for summary judgment, arguing that the undisputed facts of the case showed that Graybar was owed judgment on all claims as a matter of law. Despite the high standards of such a motion, the Court agreed with Lewis Rice granting summary judgment in favor of Graybar. As Judge Rothstein explained, “Plaintiff claims he was subjected to only a few discrete, isolated incidents, occurring many months apart during a span of over two years, which were neither extremely serious, nor frequent and pervasive, and are thus not sufficient to constitute a hostile work environment.” Judge Rothstein also held that Graybar “took timely and adequate measures in response to each complaint Copeland made.” She also rejected Mr. Copeland’s claims that Graybar terminated him on account of his race. Finally, Judge Rothstein agreed that Mr. Copeland’s claims of a pattern of workplace disruptions, which continued after his complaint to upper management, broke any causal link between his complaint and termination. In short, Mr. Copeland’s retaliation claim could not survive based solely on temporal proximity, even if that proximity was only nine days.

Lewis Rice attorneys Neal F. Perryman (Chair of the Litigation Department) and Benjamin M. Farley successfully represented Graybar. Lewis Rice was assisted by local counsel Jessica Jensen, a partner at Ogden Murphy Wallace PLLC. The decision is reported as Copeland v. Graybar Electric Company, Inc., 2:22-CV-280, 2023 WL 4421805 (W.D. Wash. July 10, 2023).