Downey v. Charlevoix Co Bd of Rd Comm'rs

In Downey v. Charlevoix Co Bd of Rd Comm'rs, 227 Mich App 621; 576 NW2d 712 (1998), the Court outlined the elements of the prima facie case of discrimination based on hostile work environment: In order to establish a prima facie case of hostile work environment, a plaintiff must prove: (1) the employee belonged to a protected group; (2) the employee was subjected to communication or conduct on the basis of the protected status; (3) the employee was subjected to unwelcome conduct or communication on the basis of the protected status; (4) the unwelcome conduct or communication was intended to, or in fact did, interfere substantially; with the employee's employment or created an intimidating, hostile, or offensive work environment; (5) respondeat superior. Id. at 629.