A Maryland federal court found that a supervisor’s comments about an employee’s accent in the context of her unsuccessful application for promotion may be evidence of discrimination based on her national origin. In Bacchus v. Price, the court acknowledged that concerns about an employee’s ability to communicate may be legitimate; however, where such concerns are unsubstantiated, they could constitute a discriminatory animus. In this case, the employee was from Guyana and her native language was English. Further, there had never previously been complaints about her communication skills.