Woodard v. PHB Die Casting’s Empirical Analysis

Citation profile

1 district ·

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 7 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “Woodard worked at defendant PHB Die Casting’s facility in Fairview, Pennsylvania, from 1998 through 2003. He contends that during that time, he experienced and heard second-hand about a number of allegedly racist comments by co-workers and that he was given less favorable job assignments than non-African American employees. Specifically, he testified at his deposition: that he saw a burning cross and KKK sign drawn on a bathroom wall in 2002, and that management failed to have it removed for at least three months after he reported it; that his supervisor consistently gave him more physically demanding tasks at more complex machines; that he was told by co-workers about blatantly racist comments that had been made by other co-workers; and that more ambiguously racially charged comments were directed to him by co-workers. In addition, Woodard introduced evidence that a supervisor at PHB’s Fairview facility agreed to attend diversity training in response to complaints in 2001 but never actually attended the class. The District Court found this evidence insufficient to establish a prima facie case for either a hostile work environment or disparate treatment claim under Title VII, 42 U.S.C. § 2000e et seq., or the Pennsylvania Human Relations Act (“PHRA”), 43 Pa. Stat. § 951 et seq. We agree.”

   1 later decision quote this exact passage · from the majority
   e.g. 667 F. Supp. 2d 535 - Mufti v. AARSAND & CO., INC.

2. “Over the course of three years, Woodard claims that he was twice asked questions using the phrase “you people,” once asked what his race was, and once asked if he intended to complete a drug deal during a bathroom break. Even assuming these somewhat ambiguous incidents were related to Woodard’s race, they are the type of offhand comments that are insufficient to support a hostile work environment claim. See Caver, 420 F.3d at 263 . 'While the KKK-related graffiti and PHB’s alleged failure to remove it promptly are more serious, this one incident, even in conjunction with the comments discussed above, is not enough for a trier of fact to conclude that discriminatory conduct in the workplace amounted to a change in the terms or conditions of Woodard’s employment.”

   1 later decision quote this exact passage · from the majority
   e.g. 667 F. Supp. 2d 535 - Mufti v. AARSAND & CO., INC.