On April 30, 2014, the United States Court of Appeals for the Ninth Circuit reinstated a lawsuit filed by Plaintiff Ronald El-Malik Curtis against the City of Oakland, and several individual city officials on the ground that facially-neutral conduct could support a finding of racial animus sufficient to sustain a hostile work environment claim when other racially-discriminatory conduct is present. (Curtis v. City of Oakland, No. 12-15831, per curiam.)