The U.S. District Court, Southern District, recently ruled that a few comments made by a supervisor to a disabled employee did not rise to the level of a hostile work environment.
The plaintiff, who worked as a Medicaid-eligibility specialist in New York City, suffered disabling knee and ankle injuries. Her supervisor made comments such as “I don’t see why you make such a fuss about your disability” and asked why she didn’t look for another job. She also once slammed the restroom door when the specialist was approaching it.
The court ruled that three comments and a door slamming over the course of two years were insufficient to constitute a hostile work environment.