Human Resources News & Insights

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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