“Acrimonious” Relationship With Supervisors Did Not Constitute Hostile Work Environment, Court Holds

In Brown v. Denis R. McDonough, in his official capacity as Secretary of Veterans Affairs, 2023 WL 3646933 (D.D.C., May 25, 2023), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s hostile work environment claim(s).

The court explained:

Although it is clear from her allegations that Ms. Brown had an acrimonious relationship with several of her supervisors—perhaps through no fault of her own—the Court concludes that her allegations, even considered in the aggregate, do not constitute a pattern of “discriminatory intimidation, ridicule, or insult” that would support a hostile work environment claim. Brooks, 748 F.3d at 1276. Although the Court does not doubt that Ms. Brown felt discriminated against when her supervisors denied her leave requests, see ECF 15 ¶¶ 31, 45, 49, 58, 61, imposed unreasonable deadlines, see id. ¶¶ 25, 32, 71, gave her worse-than-expected performance reviews, see id. ¶¶ 55, 74, or even admonished her for unfairly perceived lapses in performance, see id. ¶¶ 39, 46, those types of “work-related actions by supervisors” do not normally constitute an objectively hostile work environment under Title VII (or the ADEA). Munro v. LaHood, 839 F. Supp. 2d 354, 366 (D.D.C. 2012); see also Harris v. Mayorkas, No. 21-cv-1083 (GMH), 2022 WL 3452316, at *16 (D.D.C. Aug. 18, 2022). Similarly, the several incidents in which Ms. Brown alleges she was treated disrespectfully, sometimes in front of colleagues, see ECF 15 ¶¶ 33, 41, 43, are at most the kind of “petty insults, vindictive behavior,” and/or “angry recriminations” that courts have routinely held insufficient to sustain a hostile work environment claim. Brooks, 748 F.3d at 1277–78; see also Dieng v. Am. Insts. for Rsch. in Behav. Scis., 412 F. Supp. 3d 1, 14 (D.D.C. 2019) (dismissing hostile work environment claims based on “denial of teleworking,” “yelling at [plaintiff] during staff meetings,” “ignoring [plaintiff] at those meetings,” and “constant questioning of [plaintiff’s] work”); Singh v. U.S. House of Representatives, 300 F. Supp. 2d 48, 54–57 (D.D.C. 2004) (dismissing hostile work environment claims based on allegations that plaintiff’s employer humiliated her at important meetings, screamed at her in one instance, told her to “shut up and sit down” in one instance, and was “constantly hostile and hypercritical”).

Accordingly, the court concluded that plaintiff’s “hostile work environment allegations—which occurred on-and-off over the course of years, at the hands of multiple supervisors—fall short of establishing a pattern of conduct that was sufficiently severe or pervasive to alter the conditions of her employment.”

Moreover, while plaintiff’s allegations concerning the behavior of her supervisors and coworkers “may be probative to establish a pattern of discrimination, which would in turn be relevant to her disparate treatment claim, they do not clear the legal bar to successfully plead a hostile work environment claim.”

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