Former Employee Failed To State Claim For Hostile Work Environment Discrimination Based On Constructive Discharge

In this case granting summary judgment for the defendant, the United States District Court found that a former employee failed to establish that his working conditions were intolerable at the time of his constructive discharge, or that his employer should have foreseen his resignation at that time as the result of the conduct giving rise to the hostile work environment, as required to maintain an action under Title VII for hostile work environment discrimination resulting in constructive discharge. The alleged harassing behavior lasted between five and six weeks, and the employee did not resign until four or five months after such behavior ceased.

Winspear v. Community Development Inc.

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