Can a few isolated comments about age result in a hostile work environment?
A Rite Aid employee challenged this question in court. Here’s what the 6th Circuit had to say.
Infrequent, but rude remarks
Michael Kheibari worked at a Michigan Rite Aid as an assistant manager for four years.
Over a period of nine months, he dealt with sporadic age-based comments from his district manager, Daniel Snyder. He called Kheibari “too old”and criticized his abilities due to his age.
Kheibari made multiple attempts to address the issue. He notified a supervisor about Snyder’s behavior, had a conversation with Snyder directly and emailed Rite Aid’s CEO, but nothing changed.
He sued for age-based harassment under the ADEA, but the 6th Circuit rejected his claim. According to the court, Snyder’s conduct was rude, but due to its infrequency, it “hardly” constituted a hostile work environment.
This case shows that “stray remarks” can’t support a claim of age bias. In the workplace, however, even just one biased incident can leave a permanent stain on company culture.
Cite: Amini v. Rite Aid Corp., 7/7/20.
