Two isolated comments on a female supervisor’s hair and gender were not enough to create a sexually hostile work environment. It takes more than a handful of incidents to create hostility, even if they could be viewed as offensive and not appropriate for the workplace.
Recent case: Collette was Jimmy’s supervisor. He apparently made comments about Collette’s hair that she believed were inappropriate in the workplace. She filed an internal complaint and both were told that the comments were inappropriate.
Collette soon retired. Then she sued, alleging she had no choice but to retire, since she had been forced to work in a hostile environment.
The court dismissed her lawsuit. It reasoned that one or two comments from a subordinate were not enough to warrant quitting; they didn’t create a hostile work environment. (Campbell v. New York City Transit, No. 15-1103, 2nd Cir., 2016)