Sixth Circuit overturns dismissal of sexually hostile work environment claim; upholds dismissal of racial bias claim.

In Williams v. CSX Transportation Company, Inc., the Sixth Circuit Court of Appeals overturned a lower court's dismissal of Ms. Williams claim that she was the victim of a hostile work environment. The District Court had held that she failed to file a dcoument that met the test for a "charge" with the EEOC of sexually hostile environment and thus failed to exhaust her administrative remedies.  The higher court rejected this analysis.  Nevertheless, the court upheld the judge's decision that her evidence of a racially hostile work environment was not "severe" or "pervasive" enough to be submitted to a jury for decision.