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“Requesting reasonable accommodations is generally a protected activity against retaliation under the ADA; however, first a plaintiff must have a good faith belief that he or she was disabled or perceived as disabled.”

Williams v. Rocktenn, 2013 WL 5960671 at *14 (W.D. La. November 6, 2013) (Trimble, J.).


“Denial of ‘administrative complaints and internal grievances,’ as well as informal criticisms, or changing an employee’s work schedule or hours are ‘merely administrative decisions’ that do not constitute an ‘ultimate employment decision’ as contemplated by Title VII.”

Williams v. Shred-It, 2013 WL 596110 at *4 (E.D. La. November 7, 2013) (Roby, J.).


“When it is alleged that bigoted remarks are laughed at by fellow employees and managers, even when those remarks are not directed at the plaintiff, it becomes more likely the plaintiff will show pretext.”

Rideout v. Allstate Insurance Co., 2013 WL 6061330 at *6 (N.D. Miss. November 18, 2013) (Mills, J.).



“Relevant factors are ‘the frequency of the discriminatory conduct; its severity; whether it is physically threatening or humiliating, or a mere offensive utterance; and whether it unreasonably interferes with an employee’s work performance.”

Royal v. CCC & R Tres Arboles, 736 F.3d 396, 402 (5th Cir. November 21, 2013) (Jolly, J.).