MORRIS v. SUGARHOUSE HSP GAMING, L.P.
2:24-cv-01916
E.D. Pa.May 19, 2025Background
- Shantel Morris, a Black woman, was employed as a Count Room Attendant by SugarHouse HSP Gaming (Rivers Casino Philadelphia) and was later promoted to Count Room Lead.
- Morris received positive performance evaluations and was promoted, but later experienced alleged "nitpicking" and disciplinary actions from her White supervisor, Denise Harris, after complaining about favoritism toward another (Puerto Rican) employee.
- Morris was written up (PINs) for work protocol issues, lost key, and an error in money counting; she also reported Harris to Human Resources, claiming discrimination and retaliation.
- She alleged additional disparate treatment, including security searches related to her hairstyle and perceptions of being singled out for negative treatment because of her race.
- Morris was ultimately terminated for allegedly sleeping on the job, which Casino video evidence supported and which she denied; she then filed suit claiming race discrimination, hostile work environment, and retaliation under § 1981 and the PHRA.
- The Casino moved for summary judgment on all claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Hostile Work Environment | Harassment was racially motivated and severe/pervasive | No evidence harassment was race-based or sufficiently severe/pervasive | Not severe or pervasive; claim dismissed |
| Disparate Treatment (Termination) | Termination was due to her race | Termination was for a legitimate, non-discriminatory reason (sleeping on the job) | No inference of discrimination; claim dismissed |
| Retaliation (Section 1981) | Fired in retaliation for complaining of discrimination | No underlying § 1981 violation to support retaliation | No predicate discrimination; claim dismissed |
| Retaliation (PHRA) | Termination followed protected complaints | No causal connection between complaints and termination | Lacked causation; claim dismissed |
Key Cases Cited
- Anderson v. Liberty Lobby, 477 U.S. 242 (summary judgment standard)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden-shifting framework for discrimination claims)
- Castleberry v. STI Grp., 863 F.3d 259 (hostile work environment — severe or pervasive standard)
- Jones v. Sch. Dist. of Philadelphia, 198 F.3d 403 (PHRA and Title VII standards are coextensive)
- Caver v. City of Trenton, 420 F.3d 243 (high bar for harassment to constitute hostile work environment)
- Harris v. Forklift Sys., 510 U.S. 17 (totality of circumstances for hostile environment claims)
- Celotex Corp. v. Catrett, 477 U.S. 317 (movant's burden on summary judgment)