Northington v. H & M International

Dist. Ct. did not err in granting defendant-employer’s motion for summary judgment in Title VII action alleging that plaintiff was terminated in retaliation for making prior complaint that co-workers had harassed plaintiff. Plaintiff did not state at time of complaint that harassment was based on any protected classification, and record otherwise established that motivation for harassment was based only on personal conflict between plaintiff and co-workers. As such, plaintiff failed to show that she had engaged in protected activity to support retaliation claim.