## Facts

- Sunbelt Rentals hired Clinton Ingram, a Muslim-American, in October 2001 at its Gaithersburg, Maryland store; he later became a rental manager working at the rental counter with other managers and near the shop foreman.
- Ingram alleged that after September 11, coworkers and supervisors repeatedly subjected him to religion-based harassment, including being called “Taliban” and “towel head,” and being mocked for his kufi and beard.
- Ingram alleged coworkers linked Muslims to terrorism, questioned his loyalty to the United States, and insinuated he was a terrorist.
- Ingram alleged interference with his religious practice, including hiding his time card on Fridays when he went to prayer.
- The alleged conduct occurred frequently over an extended period, involved multiple employees (including some who sometimes served as acting managers), and occurred in a small workplace setting in front of others.
- Ingram repeatedly complained to supervisors and management, but the company allegedly failed to stop the harassment.
- Sunbelt terminated Ingram in February 2003.

## Issues

1. Whether the evidence, viewed in the EEOC’s favor, could allow a reasonable jury to find Ingram experienced unwelcome harassment based on religion that was severe or pervasive enough to alter the conditions of employment under Title VII.
2. Whether the alleged harassment could be imputed to Sunbelt based on its knowledge of the conduct and its response to Ingram’s complaints.

## Decision

- The Fourth Circuit reversed the district court’s grant of summary judgment for Sunbelt and remanded for further proceedings.
- The court held a reasonable jury could find Ingram was subjected to severe or pervasive religious harassment.
- The court held a reasonable jury could also find employer liability based on evidence that Sunbelt knew or should have known of the harassment and did not take prompt, adequate remedial action.
- The court concluded summary judgment was improper because the district court minimized incidents and failed to assess their cumulative effect, and because credibility and fact-weighing are for the jury.

## Legal Principles

- Title VII prohibits discrimination in the terms and conditions of employment, including a discriminatorily hostile or abusive work environment.
- A religious hostile work environment claim requires proof that the conduct was (1) unwelcome, (2) based on religion, (3) sufficiently severe or pervasive to alter employment conditions and create an abusive atmosphere, and (4) imputable to the employer.
- Severity and pervasiveness must be evaluated under the totality of the circumstances, including frequency, context, humiliation, and interference with work or religious practice; courts must consider the cumulative effect of incidents.
- At summary judgment, evidence must be viewed in the nonmovant’s favor; courts may not resolve credibility disputes or weigh competing inferences.
- Employer liability may be found where the employer knew or should have known of harassment and failed to take prompt and effective remedial action; involvement of supervisors or acting managers can support imputation.

## Conclusion

The Fourth Circuit held that the EEOC produced enough evidence for a jury to find that repeated anti-Muslim slurs, stereotyping, and interference with religious practice created a severe or pervasive hostile work environment and that the employer could be liable given its alleged failure to respond effectively, requiring trial rather than summary judgment.


Equal Emp. Opportunity Comm'n v. Sunbelt Rentals, Inc., 521 F.3d 306 (4th Cir. 2008)