Minor incidents add up to major trouble in ‘hostile environment’ suit
When it comes to workplace harassment claims, little things do, indeed, mean a lot.
Hostile work environment cases can be tricky – after all, there’s no objective line where a series of incidents becomes severe or pervasive.
Cumulative effect
But as this case shows, even if individual incidents don’t add up to a hostile work environment, they can do so when taken collectively.
Anna Hall sued the city of Chicago, alleging a hostile work environment. Specifically, Hall said that because she was the only female plumber in the Department of Sewers, her manager:
- assigned her menial work, including alphabetizing files and videos
- prohibited colleagues from interacting with her
- made inappropriate comments, including that he could “slap that woman and get a promotion,” and
- purposely bumped into her in the hallway one day.
Hall complained, but her manager dismissed the complaints. So she sued.
A lower court took each incident separately, concluding that none added up to a hostile work environment.
On appeal, a circuit court said it was improper to “carve up the incidents” and analyze each individually.
Taken together, the court ruled, the incidents were severe and pervasive enough to constitute a hostile work environment.
The case is Hall v. City of Chicago.
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