In Daniel v. T&M Protection Resources the Second Circuit recently found that a single racial slur may be sufficient to make a claim of a hostile work environment. The 2nd Circuit relied on a recent observation by the same court, in dicta, that “perhaps no single act can more quickly alter the conditions of employment and create an abusive working environment than the use of an unambiguously racial epithet such as ‘nigger’ by a supervisor in the presence of his subordinates.” Rivera v. Rochester Genesee Reg’l Transp. Auth., 743 F.3d 11, 24 (2d Cir. 2014).  The Second Circuit did not ultimately rule on the facts of the case, but said that it could possibly create a hostile work environment.