This manager's actions were definitely inappropriate — but were they harassment?

A male manager put his arm on a staffer’s shoulder and leg. Was that enough to sway a court to call it sex harassment? 
Nicole Ponte was hired by Steelcase to work as an area manager in New England.
Ponte immediately began having performance problems, and a CEO of a company she was dealing with even emailed the company outlining Ponte’s issues.
Soon after that, Ponte attended training at Steelcase headquarters in Grand Rapids, MI. After training ended one evening, Ponte and her male supervisor went out for dinner. Following dinner, her manager insisted he drive Ponte back to the hotel.
During the roughly 15-minute drive, the manager reached his arm around Ponte’s seat to put his hand on her right shoulder, and left his hand there for about a minute. During that ride, he emphasized to Ponte that he had done a lot to get her the job, and that she owed it to him to do “the right thing by him.”
Later during Ponte’s training in Grand Rapids, she and the male manager attended a dinner with a group of Steelcase employees. On this drive back to the hotel, the manager again reached his arm around Ponte to rest his hand on her shoulder, and kept his hand there for the majority of the 15- to 20-minute drive. Ponte didn’t request that he remove his hand, didn’t report the incident to her peers and didn’t tell her other supervisors about it.
Ponte’s problems continued, and some months later, she was fired for poor sales performance.

Was it a hostile work environment?

Ponte later sued, claiming sexual harassment.
No way, said the First Circuit.
Yes, the court said, it’s true that isolated incidents can, on occasion, qualify as sexual harassment.
But Ponte’s contact with her manager in Grand Rapids wasn’t egregious, or so egregious as to make it a hostile work environment. As the court said,

On the scale of what has been recognized as egregious conduct rising to the required level, this was not close … No reasonable jury could conclude that these incidents “amount[ed] to a change in the `terms and conditions of employment” … or created a hostile work environment. The record does not support a finding that the two incidents interfered with Ponte’s job performance.

Attorneys with Parker Poe Adams and Bernstein had the following takeaway:

This decision does not mean that employers should ignore less egregious forms of inappropriate behavior. If left unaddressed, this conduct can eventually reach the harassment threshold through repetition or escalation. However, when defending claims from employees or former employees, the lack of particularly severe conduct or the absence of repetition of lower level behavior over a period of time can prove fatal to the plaintiff’s claims.

The case is Ponte v. Steelcase, Inc.