A Title VII claim is not established when claiming a single comment, which did not affect the conditions of employment.

On two occasions the plaintiff’s assistant general manager told plaintiff to “speak English.” The plaintiff reported the comments to the general manager, who spoke to the assistant general manager and issued the assistant general manager a written warning. The assistant general manager apologized to the plaintiff for the comment. Shortly thereafter, the plaintiff was terminated for misconduct. He asserted a wrongful termination claim and a claim of a hostile work environment. In dismissing the complaint, District Judge Bumb held that, while in certain egregious circumstances a single comment may be sufficient to sustain a hostile work environment claim, the comments at issue, while inappropriate, were insufficient to sustain a claim since they did not affect the conditions of employment.

_{Case Law Alerts, 2^nd Quarter, April 2018}

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