On December 22, 2025, the United States Court of Appeals for the Eleventh Circuit held that Walmart was entitled to summary judgment as to claims of hostile work environment, religious discrimination, and retaliation from a former employee and Russian immigrant, affirming a ruling from the United States District Court for the Southern District of Alabama in Mukhina v. Walmart, Inc.

In this case, Mukhina is a Russian national and adherent to Russian Folk Christianity. She was hired by Walmart to work in the apparel section. Mukhina has limited English proficiency and alleges that she was mocked and treated poorly by customers and coworkers due to her difficulty with English. After complaining of this treatment, Walmart moved her to the night shift, which somewhat improved her working conditions, outside of isolated incidents. Mukhina later requested New Year’s Eve off, telling Walmart that it was an important holiday for Russians comparable to Christmas. Walmart denied the request because of its first come, first serve policy. Walmart gave Mukhina attendance violation points when she took the day off. Mukhina later filed an ethics complaint and then left her position.

The District Court granted summary judgment to Walmart, which was affirmed by the Eleventh Circuit. On Mukhina’s claims of hostile work environment due to national origin, the Circuit Court held that Title VII protects “immutable characteristics” and not language preference or cultural practices. As such, any harassment on account of Mukhina’s inability to speak English on its own was not sufficient to establish national origin discrimination. They further held that Mukhina’s allegations were not sufficiently severe or pervasive, and that Walmart took prompt corrective action by transferring her to the night shift.

With regard to Mukhina’s claim of religious discrimination, the Court held that Mukhina failed to exhaust her administrative remedies because her EEOC charge did not mention religious discrimination or her request for New Year’s Eve off. The Court affirmed that a Title VII action is limited to the scope of the EEOC charge. Mukhina did mention the New Year’s Eve incident in the EEOC’s intake questionnaire, but the questionnaire could not be substituted for a formal Charge of Discrimination. Further, the questionnaire described New Year’s Eve in cultural rather than religious terms.

Lastly, Mukhina’s retaliation claim failed because Mukhina failed to establish a causal connection between her protected activity and any adverse employment action. The attendance violation points were given to her because she missed work, not because she requested the day off or made an ethics complaint.

This case highlights the importance of a Plaintiff’s EEOC charge as a tool to limit the scope of Title VII litigation. Further, it emphasizes the Eleventh Circuit’s narrow interpretation of national-origin to exclude language proficiency.