In this unpubished opinion, the Eleventh Circuit after oral argument per curiam affirms Judge Cooke's Order granting Defendant Miami Beach's motion for judgment as a matter of law.
[w]e conclude that the evidence at trial was not sufficiently severe or pervasive to alter the terms and conditions of plaintiff’s employment. For example, at oral argument, it was noted that the district court may have erred in suggesting that the number of gender-based remarks were only three or four. Nevertheless, there were very few, and fewer still that were egregious (e.g., the single “bimbo” and the two “cunt” remarks which we note gave rise to a prompt reprimand.) We agree with the district court that the incidents were far short of severe or pervasive.Pshaw! That sounds like morning coffee klatsch at the first two firms at which I worked back in the day (without the prompt reprimand.) Judge Cooke seems to always get it right.
In other news, Scout Willis has turned out just fine.