Washington Court of Appeals Employee Must be Working at Office to Establish Hostile Working Environment Claim

When Plaintiff was terminated by the Washington Attorney General?s office for a raft of subpar work performance, she sued for race, ethnicity, and national origin discrimination. ?However, the trial court granted summary judgment to her employer finding that she failed to present any evidence of disparate treatment, that her hostile environment claim was barred by the statute of limitations, and that her motion to compel discovery was unsupported and would not have produced discovery that would have precluded summary judgment.?? The Court of Appeals affirmed on all grounds and held that although the Plaintiff?s termination?? took?? place?? within?? the?? limitations period, it could not count toward her hostile environment ?claim? because ?she ?had ?been reassigned to work from her home so ?could not have been subjected to a hostile work environment if she was not at work.? Clarke v. State of Washington, No. 33333-3-II (Van Deren, Quinn- Brintnall, Hunt, 6/27/06).