Walton + Brown LLP Secures Landmark Decision in Columbus “Noose” Case
COLUMBUS, OH (October 22, 2025) — Walton + Brown LLP has secured a major civil rights victory in Croley v. JDM Services, L.L.C., d/b/a Frank Road Recycling Solutions, 2025-Ohio-4762 (10th Dist. Oct. 16, 2025). The Ohio Tenth District Court of Appeals reversed the trial court’s ruling and held that the display of a single noose in the workplace can constitute severe racial harassment and create a hostile work environment under Ohio law. You can read the full decision here.
In its opinion, the Court wrote: “The question becomes whether the act of hanging a noose on the vehicle assigned to an African American male, on his second day of work at the facility, is severe enough conduct to support a hostile work environment claim. We unequivocally answer this question in the affirmative.” The Court further described the noose as “among the most repugnant of all racist symbols because it is an instrument of violence” and “a symbol not just of racial disapproval, but of terror.”
The case began when Jhalil Croley, an African American employee, discovered a noose hanging on the compactor he was assigned to operate at a landfill. When management instructed him to turn it over or allow it to be cut, he refused, explaining that he did not trust the situation would be handled appropriately. He was terminated shortly afterward. The appellate court held that his refusal could constitute protected activity and that his termination raised genuine issues of fact requiring a trial.
This decision is significant because many courts (in Ohio and across the nation) have previously ruled that a single act of racial harassment is not sufficient to create a hostile work environment. The trial court in this case had followed that reasoning when initially dismissing Mr. Croley’s claims. The appellate court’s reversal sets an important precedent, recognizing that even one act—when it involves a symbol as violent and threatening as a noose—can be severe enough to support a workplace discrimination claim.
“This decision sends a clear message that racial intimidation in the workplace will not be tolerated,” said Chanda L. Brown, lead trial attorney and Partner at Walton + Brown LLP. “Our client showed tremendous courage by standing up for himself and others. This ruling proves that even as many workplaces move to end diversity, equity, and inclusion programs, the law remains the same. Discrimination is illegal, retaliation is illegal, and justice still matters.”
Mr. Croley shared, “When I found that noose, I knew what it meant. I was scared, but I also knew I could not stay silent. No one should have to work in fear. This decision gives me hope that speaking up was worth it. Not just for me, but for anyone who has ever been made to feel less than human at work.”
About Walton + Brown LLP
Walton + Brown LLP is a Columbus-based civil rights and personal injury law firm dedicated to fighting for victims of discrimination, workplace harassment, wrongful death, police misconduct, and systemic injustice. The firm is known for handling complex, high-profile cases and achieving results that drive real change.