Mahran v. Advocate Christ Medical Center

Dist. Ct. did not err in granting defendant-employer’s motion for summary judgment in plaintiff-employee’s Title VII action, alleging that defendant subjected him to hostile work environment based on his race, Muslim religion and national origin. While plaintiff contended that defendant created hostile work environment by denying him specialized training, rejecting his request for vacation time, hiring non-Muslims as full-time pharmacists before him and disciplining/terminating him, plaintiff failed to establish that any of said incidents amounted to objectively offensive harassment based on his race, religion or national origin. Moreover, each incident had neutral basis that was unrelated to plaintiff’s protected classifications. Also, plaintiff waived any argument that his religious-accommodation claim should be reinstated because Dist. Ct. failed to consider fact that defendant’s failure to accommodate his religious practice is itself actionable regardless of whether adverse action resulted, since plaintiff expressly agreed in Dist. Ct. proceedings that prima facie case for his religious accommodation claim required showing that he suffered adverse employment action as result of his unaccommodated religious practice.