Barbara Tipps, a school bus driver for Laidlaw Transit Services in Springfield, was part of a group of employees who enjoyed a casual, friendly relationship at work. Tipps often engaged in light sexual banter and even physical cavorting, sitting on co-workers’ laps and tolerating the occasional pat on the rear.
One day, co-worker John Hull gave a vibrator to another male co-worker, asking him to give it to Tipps as a “gag gift.” The gift offended Tipps, who reported the incident immediately to the branch manager by laying it on her desk.
The manager was “stunned.” She questioned Hull, who admitted giving Tipps the toy, saying it was just part of “the daily joking around and smart-aleck comments we all make among the group.” The manager felt Hull seemed “genuinely sorry” and “upset that he had offended” Tipps.
Laidlaw investigated. Because of the history of sexual joking the group had enjoyed, the company issued letters to both male employees advising them to adhere to the company’s sexual harassment policy or face discipline. After that, no employees committed further offenses against Tipps.
Tipps sued for sexual harassment. The court dismissed her case, noting there was only one incident of “unwelcome conduct,” and Laidlaw addressed it appropriately.
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