“Snickering” and “Under the Breath” Comments Held Insufficient to Establish Hostile Work Environment
In Sanderson v. NY State Electric & Gas Corp., No. 13-1603-cv (2d Cir. Mar. 27, 2014) (Summary Order), the Second Circuit affirmed the dismissal of plaintiff’s sex-based hostile work environment, disparate treatment, and retaliation claims. Plaintiff worked as a gas fitter for defendant. Initially, she worked on the day shift as the only woman of…
Read More “Snickering” and “Under the Breath” Comments Held Insufficient to Establish Hostile Work Environment