In Case v. Onondaga Cty., No. 5:14-cv-272, 2016 WL 6781237 (N.D.N.Y. Nov. 16, 2016), the court granted defendants’ motion for summary judgment on plaintiff’s sexual harassment/hostile work environment and retaliation claims under Title VII of the Civil Rights Act of 1964.
As to plaintiff’s harassment claim, the court explained:
Here, assuming, without deciding, that [alleged harasser] Morse’s conduct created a hostile work environment, defendants provided a reasonable avenue of complaint and took appropriate remedial action. First, defendants had a policy against sexual harassment, which Case received training on and had previously invoked when she filed a complaint against another employee. Second, the personnel office made diligent efforts to investigate Case’s vague allegations. After Case informed Joyce about her complaint against Morse on April 27, 2012, he immediately notified the personnel office. That same day, Case was encouraged to file a formal complaint and, once filed, the personnel office explained how it would investigate her claim. Defendants also separated Case and Morse by assigning them to different shifts during the investigation. Then, the personnel office interviewed Morse and informed him of the penalties, however, no further action could be taken because the complaint lacked specificity. Case cannot rely on information that she failed to include in her complaint nor can she point to subsequent action taken against Morse to show that defendants were negligent in their investigation. … Defendants also cannot be held liable because Case is unsatisfied with how the investigation was handled or its results.