Chazz Roberts v. Glenn Industrial Group, Inc., 998 F.3d 111

Roberts, a male dive-tender for Glenn Industrial, alleged repeated same-sex derogatory slurs, sexually explicit comments, and at least two physical assaults by his male supervisor, Andrew Rhyner.
Roberts complained multiple times to onsite supervisors and to Ana Glenn (HR VP), but never directly to CEO Richard Glenn; Rhyner was not disciplined and the conduct continued.
Roberts had two safety incidents (one burn; one removal from a job site for observed incoherence); Glenn met with Roberts after the second incident and thereafter discharged him for safety-policy violations.
Roberts filed an EEOC charge alleging sex discrimination and retaliation; EEOC issued a right-to-sue letter and Roberts sued under Title VII. The district court granted summary judgment for Glenn Industrial on both hostile-work-environment (same-sex harassment) and retaliation claims.
On appeal, the Fourth Circuit vacated summary judgment as to the same-sex sexual harassment claim (finding the district court misapplied Oncale and ignored relevant evidence) but affirmed summary judgment as to retaliation (finding no causal link because the decisionmaker lacked knowledge and the temporal gap undercut inference of retaliation).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Roberts established same-sex hostile-work-environment sexual harassment under Title VII	Oncale’s listed examples are non-exhaustive; harassment can be proved by sex-stereotyping and by physical assaults forming part of sex-based discrimination	Oncale limits proof to its three illustrative categories (e.g., harasser homosexual or explicit sexual proposals); Rhyner is straight and assaults were not sexual	Vacated SJ as to harassment. Oncale’s examples are illustrative, not exclusive; Bostock and sex-stereotyping theories may support a same-sex claim. Remand for full hostile-environment analysis.
Whether Roberts established Title VII retaliatory discharge	Complaints to supervisors and HR put the employer on notice; constructive knowledge suffices to show causation	CEO/decisionmaker Glenn lacked actual knowledge of complaints; three-month gap plus legitimate safety reason negates causal inference	Affirmed SJ for defendant. No prima facie causation: decisionmaker lacked actual knowledge and temporal proximity was insufficient.

Oncale v. Sundowner Offshore Services, Inc., 523 U.S. 75 (recognizing same-sex harassment claims under Title VII and providing illustrative evidentiary routes)
Bostock v. Clayton County, 140 S. Ct. 1731 (Title VII forbids discrimination based on sexual orientation and gender nonconformity because such decisions are made "because of sex")
Harris v. Forklift Sys., Inc., 510 U.S. 17 (hostile work environment standard; severe or pervasive test)
Faragher v. City of Boca Raton, 524 U.S. 775 (employer vicarious liability for supervisor-created hostile environment)
Burlington Indus., Inc. v. Ellerth, 524 U.S. 742 (employer defenses and vicarious liability framework in harassment cases)
Dowe v. Total Action Against Poverty in Roanoke Valley, 145 F.3d 653 (4th Cir.) (requiring decisionmaker knowledge of protected activity to establish retaliation causation)
Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment standard)