Disclaimer:
The case on which this summary is based may no longer be current law.
Also, if the case was decided on summary judgment, the court recited the
"facts" in the light most favorable to the non-movant, which may not be
the true facts.
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General hostility and comments
by a supervisor do not qualify as actionable adverse employment actions
unless the hostility was severe and pervasive.
Griffin v.
Potter, 356 F.3d 824 (7th Cir.
February 3, 2004) - This is a Title VII retaliation action. Doris Griffin
was an EEO counselor for the Postal Service. Her retaliation claim fails
because the Seventh Circuit holds that she was not subjected to an adverse
employment action. Griffin's evidence was as follows: (1) she had a shift
change in 1996; (2) her commute was lengthened by a 2001 transfer; (3)
the Postal Service unfairly disciplined her; (4) it substituted a favorable evaluation for a more
favorable one; (5) it issued her letters of warning; (6) it assigned her to
difficult cases and gave her additional work; (7) it refused to approve annual
leave requests when work was backlogged; and (8) it denied her a parking permit
for approximately four days. Also, the Court holds that general hostility and comments by a
supervisor do not qualify as actionable adverse employment actions unless
the hostility was severe and pervasive. Editor's Note: Does Seventh Circuit
mean "severe and pervasive" or "severe or pervasive?" Click
here to see actual case.