context: Unfortunately, many employees have to put up with some amount of rude, arrogant or even boorish behavior at work and endure criticism from their bosses. The Seventh Circuit has held that being addressed in a loud and unprofessional tone during one or two meetings does not satisfy the requirement that the offensive conduct be severe and pervasive.
citation_a.signal: see
citation_a.identifier: 10 F.3d 526, 533, 537
citation_a.parenthetical: noting that "relatively isolated instances of non-severe misconduct will not support a hostile work environment claims" and holding that a supervisor's conduct, though "inappropriate and unprofessional," was not "so serious or pervasive that it created a hostile work environment within the meaning of Title VII"
citation_a.sentence: See e.g., Atanus v. Perry, 520 F.3d 662, 676 (7th Cir.2008) (citing Moser v. Indiana Dep’t of Corr., 406 F.3d 895, 903 (7th Cir.2005)); Saxton v. Am. Tel. & Tel. Co., 10 F.3d 526, 533, 537 (7th Cir.1993) (noting that “relatively isolated instances of non-severe misconduct will not support a hostile work environment claims” and holding that a supervisor’s conduct, though “inappropriate and unprofessional,” was not “so serious or pervasive that it created a hostile work environment within the meaning of Title VII”); see also Faragher v. City of Boca Raton, 524 U.S. 775, 788, 118 S.Ct. 2275, 141 L.Ed.2d 662 (1998)(remarking that Title VII is not a code of “general civility”).
citation_b.signal: see also
citation_b.identifier: 524 U.S. 775, 788
citation_b.parenthetical: remarking that Title VII is not a code of "general civility"
citation_b.sentence: See e.g., Atanus v. Perry, 520 F.3d 662, 676 (7th Cir.2008) (citing Moser v. Indiana Dep’t of Corr., 406 F.3d 895, 903 (7th Cir.2005)); Saxton v. Am. Tel. & Tel. Co., 10 F.3d 526, 533, 537 (7th Cir.1993) (noting that “relatively isolated instances of non-severe misconduct will not support a hostile work environment claims” and holding that a supervisor’s conduct, though “inappropriate and unprofessional,” was not “so serious or pervasive that it created a hostile work environment within the meaning of Title VII”); see also Faragher v. City of Boca Raton, 524 U.S. 775, 788, 118 S.Ct. 2275, 141 L.Ed.2d 662 (1998)(remarking that Title VII is not a code of “general civility”).