Blagg v. S.T.O.F.F.E. Fed. Credit Union

Citations

• 248 N.E.3d 313
• 2024 Ohio 2579

Syllabus

Summary judgment Civ.R. 56 employer R.C. 4112.01(A)(2) racial harassment hostile work environment R.C. 4112.01(A) severe or pervasive retaliation R.C. 4112.02(I) termination voluntary resignation failure to investigate aiding and abetting retaliation R.C. 4112.02(J). Trial court did not err in granting summary judgment in favor of appellees on appellant's claims of a hostile work environment in violation of R.C. 4112.02(A), retaliation in violation of R.C. 4112.02(I) and aiding and abetting retaliation in violation of R.C. 4112.02(J). Where credit union employed four employees in Ohio at the time of the alleged racial harassment at issue, credit union was an employer for purposes of appellant's hostile-work-environment claim under R.C. 4112.01(A)(2) and 4112.02(A). Even assuming appellant, a white woman, subjectively perceived her workplace to be a racially hostile work environment, there was no genuine issue of fact that a reasonable person would not find appellant's work environment to be objectively racially hostile. The evidence appellant presented involving black coworkers' discussion of race and race-related current events following the murder of George Floyd, offhand comments relating to race and the playing of videos of protests of violence against blacks, which appellant stated made her uncomfortable, was not sufficiently severe or pervasive to create an objectively racially hostile work environment. Because the only reasonable conclusion that could be drawn from the evidence was that appellant voluntarily quit her employment at the credit union and appellant did not present evidence showing a causal connection between her filing a discrimination charge with the Ohio Civil Rights Commission and the credit union's alleged mishandling of her account funds, appellant could not recover on retaliation claims against the credit union. Appellant could not prevail on retaliation claim based on appellee's failure to investigate her harassment complaint because the a