Case Explained: Non-Argument Calendar WENDY MIKELL v. POSTMASTER GENERAL, U.S. POSTAL SERVICE

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-06-22 Docket: 5:24-cv-00039-LGW-BWC The eleventh-circuit affirmed the district court’s dismissal of Wendy Mikell’s second amended complaint for failure to state a claim of hostile work environment under Title VII of the Civil Rights Act of 1964. The court held that the alleged discriminatory acts occurring in 2022 were untimely because Mikell failed to file suit within 90 days of receiving her right-to-sue notice following her first EEO complaint, and these untimely acts were not sufficiently related to the timely acts from 2023 and 2024 to be fairly considered part of the same hostile work environment claim. Applying the standard set forth in *National Railroad Passenger Corp. v. Morgan* and *Chambless v. Louisiana-Pacific Corporation*, the court found the 2023 confrontation occurred outside of work, involved off-duty individuals, and was not sufficiently similar to the earlier alleged acts to revive them. Furthermore, the court concluded that the timely acts alone—the 2023 teller machine incident and the 2024 letters—failed to state a claim because Mikell did not establish that these events were motivated by race or that they were severe or pervasive enough to alter the conditions of her employment under the objective and subjective standards required for such claims. As a result, the dismissal stands, and Mikell is barred from pursuing this litigation. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.