Singh's comments created a hostile work environment under Title VII. Satterwhite's activities to be protected, he would have to reasonably believe that Mr. Satterwhite claimed that he engaged in two protected activities: (1) reporting the "Heil Hitler" comment to human resources and (2) responding to inquiries regarding OIG's investigation of the "Heil Hitler" comment.
In doing so, it noted that in order to establish a prima facie case of retaliation under Title VII, an aggrieved employee must show: (1) he engaged in an activity protected by Title VII (2) he was subjected to an adverse employment action and (3) a causal link exists between the protected activity and the adverse employment action. The Fifth Circuit Court of Appeals affirmed. Satterwite was unable to show that his reports of the "Heil Hitler" comment was the proximate cause of his demotion. The district court granted summary judgment to the City because Mr. Singh's "Heil Hitler" comment to human resources. Satterwhite brought a suit alleging that he was unlawfully retaliated under Title VII and corresponding state statutes for reporting Mr. Singh was demoted to an Assistant City Controller IV and his salary was lowered by two pay grades. Satterwhite in several instances and recommended that he be demoted. Martina Lee that they were not running a Hitler Court," which violated an executive order of the mayor of Houston prohibiting a city employee from using such offensive words. Singh's reported conduct and concluded that "Singh made a comment to Ms. The next month, the City Controller's Office and City Office of Inspector General (OIG) received letters from the Anti-Defamation League, which complained of the "Heil Hitler" comment by Mr. Satterwhite began reporting directly to Mr. Singh was verbally reprimanded and later discovered that Mr.
Singh's comment and reported the incident to human resources. City of Houston, Harry Singh allegedly used the phrase "Heil Hitler" in a meeting attended by employee Courtney Satterwhite. Court of Appeals for the Fifth Circuit held that one offensive comment was insufficient to create a hostile work environment. Does a single incident create a hostile work environment? Just this month, the U.S.
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