Octavia Poteat v. CP Development

CourtCourt of Appeals for the Third Circuit
DecidedJanuary 13, 2026
Docket24-3290
StatusUnpublished

This text of Octavia Poteat v. CP Development (Octavia Poteat v. CP Development) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Octavia Poteat v. CP Development, (3d Cir. 2026).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT _____________

No. 24-3290 _____________

OCTAVIA POTEAT, Appellant v.

CP DEVELOPMENT, doing business as REGENT SQUARE RENTALS; JAMES POLINSKY _____________

On Appeal from the United States District Court for the Western District of Pennsylvania (D.C. No. 2:24-cv-00482) District Judge: Honorable William S. Stickman, IV _____________

Submitted Pursuant to Third Circuit L.A.R. 34.1(a) November 12, 2025 _____________

Before: SHWARTZ, MATEY, and MONTGOMERY-REEVES, Circuit Judges.

(Filed: January 13, 2026) _____________

OPINION * _____________

This disposition is not an opinion of the full Court and, pursuant to I.O.P. 5.7, *

does not constitute binding precedent. MATEY, Circuit Judge.

Octavia Poteat sued her former employer and its manager for alleged racial

discrimination, asserting hostile work environment and retaliation claims under 42 U.S.C.

§ 1981. The District Court dismissed Poteat’s claims with prejudice and, seeing no error,

we will affirm.

I.

In April 2023, CP Development hired Octavia Poteat, an African American

woman, as a Property Manager for an apartment complex in Pittsburgh. James Polinsky

was CP Development’s General Manager.

Poteat claims that, shortly after she was hired, co-worker Barbara Jacobs made the

“following racially charged and discriminatory comments” on several different occasions

in Poteat’s presence: 1) “that Hispanics [are] rude”; 2) “that African Americans, in her

opinion, were more likely to fraudulently fill out apartment application documents”; 3)

regarding immigration, “I don’t know where they’re coming from, but they’re all coming

over. You know, those Indians or Arabs, whatever they are”; 4) that Mexican women are

“fiery” and that “Mexicans are taking over our jobs”; 5) about an African-American

coworker, “look at Denzel, isn’t he one of those beautiful black men?”; and 6) “on one

occasion where the employees were watching a true crime documentary about missing

people of color, possible murder victims[:]‘that would never happen in my

neighborhood’.” App. 32, 50–51.

Poteat claims that she complained to Polinsky about Jacobs’ comments multiple

times, and that he promised to “handle the situation.” App. 52. But on September 28,

2 2023, Poteat’s difficulties with Jacobs escalated when, during a morning meeting at

which Polinsky was also present, Jacobs yelled at Poteat to “just do what they tell you. If

they are telling you to do something, it is for a reason.” App. 53. Poteat alleges that

Polinsky failed to intervene until she “began to speak up for herself,” telling her and

Jacobs “that they were both in the wrong.” App. 53. Even though Poteat asked Polinsky

to connect her with Human Resources after the incident, he failed to do so.

The day after this altercation, Poteat received a final notice for poor performance,

although she alleged it was her first notice. Soon after, she was terminated, days before

she would have received a $1,000 signing bonus. Poteat claims that this reason was

pretextual and that Polinsky terminated her in retaliation for reporting “racial

discrimination and a racially hostile work environment.” App. 54.

Poteat then sued CP Development and Polinsky, asserting a hostile work

environment claim (Count I) and a retaliation claim (Count II), both under 42 U.S.C. §

1981. 1 She later filed an amended complaint, asserting the same two claims. Defendants

moved to dismiss her amended complaint, to which Poteat filed a substantive opposition.

While the motion to dismiss was pending, Poteat filed a motion for leave to file a second

amended complaint to add Title VII hostile work environment and retaliation claims

1 Section 1981 protects the right of “[a]ll persons within the jurisdiction of the United States . . . to make and enforce contracts, to sue, be parties, give evidence, and to the full and equal benefit of all laws and proceedings for the security of persons and property as is enjoyed by white citizens.” 42 U.S.C. § 1981(a). 3 against CP Development. The District Court granted Defendants’ motion to dismiss with

prejudice, simultaneously denying Poteat’s motion to file a second amended complaint. 2

II.

We will affirm the District Court in full. The District Court properly dismissed

Poteat’s hostile work environment claim. Our decisions allow a plaintiff to bring a

Section 1981 claim if she suffered a “hostile work environment on the basis of race,”

reasoning that such an environment can “amount to a change in the terms and conditions

of employment.” Castleberry v. STI Grp., 863 F.3d 259, 263–64 (3d Cir. 2017) (quoting

Faragher v. City of Boca Raton, 524 U.S. 775, 788 (1998)). But to make out that claim, a

plaintiff must show: 1) “intentional discrimination because of [the plaintiff’s] race” that

2) was “severe or pervasive” and that both 3) “detrimentally affected the plaintiff” and 4)

“would detrimentally affect a reasonable person in like circumstances,” as well as 5) “the

2 The District Court had jurisdiction under 28 U.S.C. § 1331, and we have jurisdiction under 28 U.S.C. § 1291. We review the grant of a motion to dismiss de novo. Wheeler v. Hampton Twp., 399 F.3d 238, 242 (3d Cir. 2005). Dismissal is appropriate when the complaint’s “factual matter, accepted as true,” fails “to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). When reviewing a dismissal at the pleading stage, we “accept all factual allegations in the complaint as true and view them in the light most favorable to the plaintiff.” Doe v. Princeton Univ., 30 F.4th 335, 340 (3d Cir. 2022) (quoting Umland v. PLANCO Fin. Servs., Inc., 542 F.3d 59, 64 (3d Cir. 2008)). But we “disregard legal conclusions and recitals of the elements of a cause of action supported by mere conclusory statements.” Davis v. Wells Fargo, 824 F.3d 333, 341 (3d Cir. 2016). 4 existence of respondeat superior liability.” Id. at 263 (quoting Mandel v. M & Q

Packaging Corp., 706 F.3d 157, 167 (3d Cir. 2013)).

Poteat’s allegations fail to clear this high bar. Jacobs’ tone-deaf comments are not

by themselves severe or pervasive enough to create a racially-prejudiced hostile work

environment for Poteat. As we have explained, “offhanded comments, and isolated

incidents (unless extremely serious),” Caver v. City of Trenton, 420 F.3d 243, 263 (3d

Cir. 2005) (quoting Faragher, 524 U.S.

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Related

Faragher v. City of Boca Raton
524 U.S. 775 (Supreme Court, 1998)
Estate of Oliva Ex Rel. McHugh v. New Jersey
604 F.3d 788 (Third Circuit, 2010)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Mandel v. M & Q Packaging Corp.
706 F.3d 157 (Third Circuit, 2013)
Umland v. PLANCO Financial Services, Inc.
542 F.3d 59 (Third Circuit, 2008)
Caver v. City of Trenton
420 F.3d 243 (Third Circuit, 2005)
Atron Castleberry v. STI Group
863 F.3d 259 (Third Circuit, 2017)
John Doe v. Princeton University
30 F.4th 335 (Third Circuit, 2022)
Davis v. Wells Fargo, U.S.
824 F.3d 333 (Third Circuit, 2016)

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