Chowdhury v. Bair (D.D.C. 2010): Religious Discrimination in the Workplace

Plaintiff Sultan Chowdhury sued his employer under Title VII for discrimination, retaliation, and creating a hostile work environment. In this action, the Court reviewed the defendant’s supplemental motion for summary judgment based on plaintiff’s hostile work environment claim. (The defendant had previously filed a motion for summary judgment that was dismissed on the discrimination and retaliation claims, and the Court ordered further briefing for the hostile work environment claim.) The plaintiff also amended his previous claim, detailing the hostile work environment claims, alleging discrimination on the basis of his religion (Islam), including belittling and humiliation in front of his co-workers, exclusion from important meetings, and interference with his attempts to seek transfer. The Court held that the named instances provided sufficient evidence for jurors to find that the conduct was severe or pervasive enough to allow a hostile work environment claim. It therefore denied the defendant’s motion for summary judgment, allowing the case to move forward to trial. On March 7, 2011, a jury trial delivered a partial verdict in the case, as the jury did not answer all of the questions raised but awarded compensatory damages in the amount of $1,125,000. The Court directed the parties to file a joint status report in August 2011 if they were seeking mediation on the outstanding issues.

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