Happy Valentine’s Day!
In keeping with what I hope will be a continued practice of keying blog posts to holidays, I present to you the case of Ashok v. Barnhart, 289 F. Supp. 2d 305 (EDNY 2003).
In Ashok, plaintiff claimed that she was subjected to retaliation and a hostile work environment based on national origin and religion (due to her Hindu faith). As relevant to today, plaintiff alleged “that she suffered harassment in February 1993 when a Valentine’s Day poster placed in her office lunchroom asked, ‘[plaintiff] loves?'”. The court held that the alleged ridicule and humiliation by the Valentines Day poster “may not reasonably be said to interfere with Plaintiff’s work or to cause her psychological harm”, and dismissed plaintiff’s hostile work environment claims.
As the hostile work environment analysis is necessarily fact-dependent, this decision should not be read to condone bringing Valentines Day (or romance in general) into the workplace, or that Valentines Day workplace antics may not give rise to liability.
There are many reasons – outlined, for example, here, here, and here – why it is a good idea to avoid workplace romances (or, more bluntly, to avoid getting your honey where you get your money).