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Harris v. Wackenhut Services, Inc.
Citation: 419 F. App'x 1Docket: No. 09-7104
Court: Court of Appeals for the D.C. Circuit; May 3, 2011; Federal Appellate Court
Judgment is affirmed in favor of Wackenhut Services, Inc. regarding Edward E. Harris's claims of a racially hostile work environment and discrimination related to his transfer. The District Court dismissed Harris's hostile work environment claim, determining that the isolated racially motivated comments did not constitute a legally actionable hostile environment, as they lacked the extreme conduct required for such a claim. The court noted that only three comments were made over a year, insufficient to establish actionable harassment. Evidence unrelated to race also failed to support his claim. For the discriminatory transfer claim, the District Court found that Harris did not provide adequate evidence to suggest discrimination. The sole evidence cited by Harris—a comment by one executive and laughter from another—was deemed insufficient to infer racial discrimination, as the comment was not directed at Harris and the laughter did not pertain to his race. Thus, Wackenhut's stated legitimate reasons for the transfer were not shown to be a pretext for discrimination. The ruling will not be published, and the issuance of the mandate is withheld for seven days following any timely petition for rehearing.