The Eight Circuit Court of Appeals’ high bar for Title VII hostile work environment claims remains after the United States Supreme Court declined to hear the case on December 7, 2020. The Eighth Circuit previously held in Paskert v. Kemna-ASA Auto Plaza, Inc, that a supervisor’s boorish behavior, “while certainly reprehensible and improper,” was not so severe or pervasive to alter the terms and conditions of employment necessary to sustain a Title VII hostile work environment claim.
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