A United States District Court for the Northern District of Texas recently granted summary judgment to an employer in an age discrimination claim. Bell v. Raytheon Co., No. 3:08-CV-0702-G (N.D. Tex. July 31, 2009), available at https://ecf.txnd.uscourts.gov/cgi-bin/show_public_doc?2008cv0702-101. Three employees of Raytheon alleged the company discriminated against them by denying one a promotion, unfairly disciplining another, and giving away the job duties of the third. The employees also alleged that a hostile work environment existed because their boss verbally abused them and treated younger employees more favorably.
The Court first found that no evidence showed the decision not to promote one employee was related to his age. The Court also found that the discipline of the second employee and the reassignment of the third employee’s job duties did not constitute adverse actions upon which age discrimination claims could be based. The Court next examined the collective hostile work environment claim. Because the employees presented no evidence that the alleged verbal abuse was related to their age and because yelling alone is insufficient to state a claim of hostile work environment, the Court granted summary judgment for the employer.
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