KellyMarie Griffin works for the City of Portland, Oregon, as a clerical employee in the Parks and Recreation Department. She complains of conflict with her coworkers. In particular, Therea Lareau, the “lead” clerical employee at the same location, has made comments that are derogatory about or offensive to Griffin’s Christian faith. Ms. Lareau has referred to Griffin as “a wacko” because of her beliefs and, on at least one occasion, told Griffin that God was “a figment of [her] imagin[ation]” and that Griffin was “praying to something that didn’t exist.” Griffin also complains that many of her coworkers frequently page 51-42use “God” and “Jesus Christ” as swear words, which she finds offensive due to her religious beliefs. Griffin, however, admits that when she has informed her coworkers about how the swearing offends her, they have made efforts to avoid doing so in her presence—even Lareau. Despite that, things have deteriorated. Recently, Griffin and Lareau found themselves in a particularly tense encounter. While another coworker was gathering her things to leave for lunch, Griffin sneezed loudly. This apparently startled the coworker, because she exclaimed, “Jesus Christ!” The coworker then left for lunch. The exclamation offended Griffin, so she commented to Lareau, the only other clerical worker in the office at the time, “I said that I objected to profanity of God’s name. I said that this type of language is not professional, I find it personally distasteful, and it is in violation of my religious convictions. I said if it didn’t stop, I would make a complaint with management.” Lareau responded in a loud, angry voice, “I’m sick of your Christian attitude, your Christian [expletive] all over your desk, and your Christian [expletive] all over the place.” She further accused Griffin of using her Christian religion to get “attention.” If Griffin files a complaint with the City claiming a violation of her rights under Title VII, how should the City respond to this complaint? Can it avoid liability under Title VII at this point?

KellyMarie Griffin works for the City of Portland, Oregon, as a clerical employee in the Parks and Recreation Department. She complains of conflict with her coworkers. In particular, Therea Lareau, the “lead” clerical employee at the same location, has made comments that are derogatory about or offensive to Griffin’s Christian faith. Ms. Lareau has referred to Griffin as “a wacko” because of her beliefs and, on at least one occasion, told Griffin that God was “a figment of [her] imagin[ation]” and that Griffin was “praying to something that didn’t exist.” Griffin also complains that many of her coworkers frequently page 51-42use “God” and “Jesus Christ” as swear words, which she finds offensive due to her religious beliefs. Griffin, however, admits that when she has informed her coworkers about how the swearing offends her, they have made efforts to avoid doing so in her presence—even Lareau. Despite that, things have deteriorated. Recently, Griffin and Lareau found themselves in a particularly tense encounter. While another coworker was gathering her things to leave for lunch, Griffin sneezed loudly. This apparently startled the coworker, because she exclaimed, “Jesus Christ!” The coworker then left for lunch. The exclamation offended Griffin, so she commented to Lareau, the only other clerical worker in the office at the time, “I said that I objected to profanity of God’s name. I said that this type of language is not professional, I find it personally distasteful, and it is in violation of my religious convictions. I said if it didn’t stop, I would make a complaint with management.” Lareau responded in a loud, angry voice, “I’m sick of your Christian attitude, your Christian [expletive] all over your desk, and your Christian [expletive] all over the place.” She further accused Griffin of using her Christian religion to get “attention.” If Griffin files a complaint with the City claiming a violation of her rights under Title VII, how should the City respond to this complaint? Can it avoid liability under Title VII at this point?