No Hostile Work Environment Based on a Single Derogatory Statement

Feeney v. Jeffries & Co., Inc., No. 09-2708 (D.N.J., June 28, 2010) – In this case the plaintiff alleged, among other things, that his supervisor directed offensive comments at him thereby creating a hostile work environment in violation of the New Jersey Law Against Discrimination. The district court rejected the plaintiff’s hostile work environment claim because the complained-of incidents were not sufficiently “severe” or “pervasive.” Specifically, the court noted that the supervisor’s comment that the plaintiff was “an ‘Irish c**ksucker’ occurred only once.” With regard to the plaintiff’s allegation that his supervisor “repeatedly” told the plaintiff that he “was lucky to have this job because of his Irish ancestry,” the court stated “‘repeatedly’ could mean that [the supervisor] made such a comment every time he saw [the plaintiff] or it could mean that he made a similar comment on as few as two occasions – without more information, it is simply impossible to tell.”