Prison guard's action of showing a "racially insensitive" drawing to an African-American prisoner, while "offensive, degrading, and reprehensible," was not "pervasive" or "severe" enough to be racial discrimination in violation of the prisoner's constitutional rights. The picture consisted a circle containing three pie pieces that were purported to represent the heads of three hooded figures, and the guard allegedly told the prisoner that it was "the last thing a black person see[s] when they fall down a well," the "KKK" looking down a well. Graves v. North Dakota State Penitentiary, 325 F. Supp. 2d 1009 (D.N.D. 2004). [N/R]
          295:99 Correctional facility had to either make a good faith effort to accommodate an officer, who was also a minister, in his request for unpaid leave to attend religious conferences, or else show that doing so would create an undue hardship; racial harassment claim was also asserted by officer. Jones v. New York City Dept. of Correction, 2001 U.S. Dist. LEXIS 2669 (S.D.N.Y.).
          291:36 African-American correctional officer could recover $100,000 in emotional distress damages, as well as back pay, after he resigned his job in response to racially hostile work environment caused by the use of racial slurs by his supervisor, also an African-American. Ross v. Douglas County, Nebraska, #00-2688, 234 F.3d 391 (8th Cir. 2000).
          248:123 District of Columbia not liable to African American correctional officer for alleged racially hostile work environment caused by African American co-workers' use of the term "nigger" to refer to him and other African Americans; plaintiff failed to bring specific complaints to the attention of management level employees. Ridley v. District of Columbia, 945 F.Supp. 333 (D.D.C. 1996).