Li Li Manatt v. Bank of America, Na

Li Li Manatt is an American citizen of Chinese descent. For two-and-a-half years, from July 1995 to March 1998, Ma-natt worked in the trade finance department of Bank of America’s Portland, Oregon, office. Manatt alleges that, during her time with this group, her eo-workers directed “numerous” racial epithets at her, and that these epithets, when viewed in the aggregate, so polluted her workplace that they created a hostile work environment. Manatt also contends that the Bank discriminated against her on account of her race by retaliating against her for various complaints that she made and by constructively discharging her.

The district court granted summary judgment in favor of the Bank on all of Manatt’s claims. Manatt now appeals, arguing that the Bank’s racial discrimination violated both Title VII of the 1964 Civil Rights Act and 42 U.S.C. § 1981 . Because Manatt’s hostile work environment claim and one of her retaliation claims are time-barred under Title VII, we must decide whether such claims are cognizable under 42 U.S.C. § 1981 . We conclude that § 1981 encompasses retaliation and hostile work environment claims, but nonetheless affirm the district court’s grant of…