Michigan court holds worker did not adequately allege hostile work environment

In Perry v. Department of Human Services, the plaintiff brought a legal action claiming that she was denied promotion and received a negative evaluation as a result of racial discrimination.  She pointed out that the events occurred at approximately the same time that a stuffed gorilla was placed on a cubicle wall that separated her work area from common areas in the office.

The Court summarily rejected her claim, holding that she did not adequately raise a claim of hostile work environment, that there was "no evidence that the placement of the gorilla was racially motivated," and that the "totality of the circumstances did not constitute proof of severe or pervasive discriminatory conduct."