Article: 3rd Circuit rules hostile work environment claim not enough for back pay award

A successful hostile environment claim, without a successful constructive discharge claim, isn't enough to support a back pay award, the 3rd Circuit has ruled.

The plaintiff, who is hearing-impaired, brought an ADA claim against Wal-Mart alleging that it didn't reasonably accommodate her disability and subjected her to a hostile work environment. A jury decided in her favor on the hostile work environment claim and awarded her $15,000 for back pay.

Wal-Mart argued that the plaintiff failed to establish a hostile work environment claim and even if she did, it wasn't sufficient to support a back pay award.

The 3rd Circuit agreed.

"We hold that a successful hostile work ...

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