MORRIS v. SUGARHOUSE HSP GAMING, L.P.
2:24-cv-01916
| E.D. Pa. | May 19, 2025Background
- Shantel Morris, a Black woman, was employed at SugarHouse HSP Gaming (Rivers Casino Philadelphia) as a Count Room Attendant and later promoted to Count Room Lead.
- Morris received positive performance feedback early on but began experiencing disciplinary actions after complaining of favoritism by her supervisor, Harris.
- Morris was disciplined multiple times (issued three “Performance Improvement Notices”) and subjected to other incidents she claimed were discriminatory, such as a headband search by security and being gifted a bottle of wine labeled “Devil.”
- The Casino terminated Morris's employment after surveillance footage allegedly confirmed she was sleeping on the job, despite her denial.
- Morris sued for racial discrimination, hostile work environment, and retaliation under 42 U.S.C. § 1981 and the Pennsylvania Human Relations Act (PHRA), and the Casino moved for summary judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Hostile work environment | Morris faced discriminatory treatment severe or pervasive enough to alter conditions | No evidence of racial animus or sufficiently severe/pervasive acts | Not severe or pervasive; summary judgment for Defendant |
| Disparate treatment (termination) | Her firing occurred under circumstances suggesting racial discrimination | Termination based on valid, non-discriminatory grounds (sleeping) | No inference of discrimination; summary judgment granted |
| Retaliation (§ 1981 and PHRA) | Terminated in retaliation for complaints about racial bias and favoritism | No causal link between complaints and termination | No causation established; summary judgment for Defendant |
Key Cases Cited
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (standard for summary judgment—genuine issue of material fact required)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden-shifting framework for discrimination claims)
- Castleberry v. STI Grp., 863 F.3d 259 (standards for hostile work environment and severe or pervasive conduct)
- Caver v. City of Trenton, 420 F.3d 243 (need for evidence linking harassment to discrimination)
- Drinkwater v. Union Carbide Corp., 904 F.2d 853 (what constitutes pervasive harassment for hostile environment claims)
- Harris v. Forklift Sys., Inc., 510 U.S. 17 (totality of the circumstances in hostile environment analysis)