Tenth Circuit States Once Again: Title VII of the Civil Rights Act Does Not Create a General Civility Code

In Musungayi v. Whirlpool Corporation, the Tenth Circuit Court once again reaffirmed the principle that Title VII of the Civil Rights Act does not create a general civility code.  The court agreed with the district court’s decision that the plaintiff had not stated a claim of discrimination despite the fact that some coworkers made stray comments about “dark Africa” and occasionally got angry with the plaintiff.