Irani v. Palmetto Health — June 2016 (Summary)

HOSTILE WORK ENVIRONMENT

Irani v. Palmetto Health
C/A No. 3:14-cv-3577-CMC (D.S.C. June 1, 2016)

The United States District Court for the District of South Carolina granted summary judgment in favor of a health system that was sued by a resident for, among other things, subjecting the resident to a hostile work environment.

The resident claimed that because of his perceived middle-eastern ethnicity, the resident’s program director repeatedly referred to him as “Achmed the Terrorist” and joked that the resident might blow up the hospital.

The court reasoned that a jury could find the program director’s comments were made because of the resident’s race.  However, because the resident could only identify two instances in which the program director referred to him as “Achmed the Terrorist,” the court stated that the comments were not enough to create a hostile work environment.  Also, the court noted that while a jury could find the program director’s language offensive, the resident failed to offer any evidence that established that the comments were made in the course of any otherwise hostile, angry, threatening, or demeaning behavior.