How many discriminatory comments does it take to create a hostile work environment? How should a manager handle vague reports of harassing conduct? These questions and more were recently addressed in Mitchell v. Kensington Community Corporation for Individual Dignity, No. 18-2869, 2019 U.S. Dist. LEXIS 205679 (E.D. Pa. Nov. 26, 2019), where the court denied summary judgment to an employer based on management’s failure to meaningfully investigate repeated, albeit somewhat vague, reports of harassment.

Long-Term Employee Resigns in Frustration

For more than 25 years, plaintiff Charles Mitchell, an African American, worked in maintenance for defendant Kensington Community Corporation for Individual Dignity (KenCCID), an in-home services provider for persons with disabilities, doing everything from simple repairs to supervising contractors. He served as the company’s sole maintenance coordinator until 2014, when KenCCID added a second coordinator: Lionel Labitan.