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6th Circuit Upholds Dismissal of Sexual Harassment Case Against CEO

The U.S. Court of Appeals for the Sixth Circuit affirmed a lower court's dismissal of sexual harassment claims against WNB Group LLC and its CEO Jay Wallis. The court ruled that plaintiff Lorna Vinsant failed to establish that alleged harassment created a hostile work environment or that retaliation occurred.

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4 min readcourtlistener
Seal of the Sixth Circuit Court of Appeals

Case Information

Case No.:
25-3228

Key Takeaways

  • Sixth Circuit affirmed summary judgment dismissing hostile work environment and retaliation claims
  • Court found alleged harassment did not meet legal standard for severity or pervasiveness under Title VII
  • Plaintiff could not remember specific harassing comments or their frequency
  • No evidence of causal connection between harassment complaints and termination established

The U.S. Court of Appeals for the Sixth Circuit affirmed summary judgment Tuesday in favor of WNB Group LLC and its CEO Jay Wallis, dismissing sexual harassment claims brought by former employee Lorna Vinsant. The three-judge panel ruled that Vinsant failed to meet the legal standard for proving either a hostile work environment or retaliation.

In the opinion authored by Circuit Judge Amul Thapar, the court held that Vinsant could not establish that the alleged harassment was severe or pervasive enough to create a hostile work environment under federal employment law. The court also found insufficient evidence of a causal connection between Vinsant's complaints and her termination from the company.

Vinsant began working for WNB Group in 2011, where she prepared invoices for customers and collected payments. She alleged that CEO Jay Wallis sexually harassed her by making comments about her appearance during her employment. However, the court noted that Vinsant could not remember specific comments Wallis allegedly made or how frequently such comments occurred.

The court emphasized several key facts that undermined Vinsant's claims. According to the opinion, Vinsant acknowledged that Wallis never touched her, asked her out, or propositioned her during her time at the company. Despite the allegedly inappropriate comments, Vinsant remained employed at WNB for five years before her departure.

To establish a hostile work environment claim under Title VII of the Civil Rights Act of 1964, plaintiffs must demonstrate that harassment was severe or pervasive enough to alter the terms and conditions of employment. The Sixth Circuit determined that Vinsant's allegations fell short of this standard.

The decision reflects the ongoing challenge plaintiffs face in sexual harassment cases, particularly in establishing that workplace conduct rises to the level of actionable harassment under federal law. Courts have consistently required that harassment be more than merely offensive or inappropriate to violate federal employment discrimination statutes.

Regarding the retaliation claim, the court found that Vinsant failed to establish the necessary causal connection between her complaints about the alleged harassment and her termination. Under federal employment law, retaliation claims require plaintiffs to show that their protected activity, such as filing harassment complaints, was a but-for cause of the adverse employment action.

The case originated in the U.S. District Court for the Southern District of Ohio, which granted summary judgment in favor of WNB Group and Wallis on both the hostile work environment and retaliation claims. Summary judgment is appropriate when there are no genuine issues of material fact and the moving party is entitled to judgment as a matter of law.

The Sixth Circuit panel, which also included Circuit Judges David McKeague and Joan Larsen Griffin, found no error in the district court's analysis. The court's affirmance means that Vinsant's claims cannot proceed to trial, and the defendants avoid potential liability for the alleged harassment.

This decision adds to the body of Sixth Circuit precedent addressing sexual harassment claims in the workplace. The circuit, which covers Kentucky, Michigan, Ohio, and Tennessee, has jurisdiction over employment disputes arising in these states.

The opinion, filed Jan. 7, 2026, was marked as not recommended for publication, meaning it will have limited precedential value in future cases. However, the decision illustrates the evidentiary challenges plaintiffs face in sexual harassment litigation.

Employment attorneys note that successful hostile work environment claims typically require documentation of specific incidents, witnesses, or other corroborating evidence. The inability to recall specific harassing comments or their frequency can significantly weaken a plaintiff's case, as demonstrated in this decision.

The ruling also underscores the importance of timing in retaliation claims. Courts closely examine the temporal relationship between protected activity and adverse employment actions, requiring plaintiffs to demonstrate more than mere coincidence to establish causation.

For employers, the decision reinforces the value of maintaining clear harassment policies and documentation practices. While WNB Group prevailed in this case, the litigation highlights the ongoing importance of addressing workplace harassment complaints promptly and thoroughly.

The case number is 25-3228, and the full citation will be *Vinsant v. WNB Group LLC* (6th Cir. 2026). Neither party has indicated plans to seek further review of the decision, and the time for filing a petition for rehearing or Supreme Court review will expire according to federal appellate rules.

Topics

sexual harassmenthostile work environmentretaliationemployment discriminationsummary judgment

Original Source: courtlistener

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