Amiri v. Stoladi Prop. Group (D.D.C. 2005): Failed Allegation of Bias at the Workplace

An Afghani Muslim security guard at a company that contracted with his former employer for his security guard services sued under Title VII and §1983, alleging discrimination based on race, religion, and national origin as well as a hostile work environment. The plaintiff claimed that, while working for the company, he was harassed by the property manager who asked him if he was from Afghanistan and if he was Muslim. The court granted the defendant’s motion to dismiss the claim, concluding that the plaintiff and defendant company did not have an employee-employer relationship, that the plaintiff failed to establish a prima facie case of discrimination, and that the alleged actions were not severe or pervasive enough to warrant a hostile work environment finding. The plaintiff made no explicit claim about Islamic law except to complain of perceived bias on the basis of his religion, which may have included ritual practices based on Islamic law.

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