On Fri, Oct 30, 2009 at 2:28 PM, Pollak, Melissa F. <[email protected]> wrote:
> P-Gage, here are the facts in the Broderick case as I see them:
>
> 1.  She only experienced a little sexual harassment herself -- when she
> first starting working at the agency.
>
> 2.  She did not think she should have to work in an environment in which
> her colleagues and their bosses were sleeping with each other -- and she
> complained about it.
>
> 3. Because she complained, she received bad performance ratings and
> wasn't promoted.  [As an aside, believe me, I know first-hand what
> happens to those who complain -- or speak up -- at a federal agency when
> things aren't the way they should be.]
>
> From the AP piece I linked:
>
> "Although Broderick herself was the victim of only isolated incidents of
> direct sexual overtures, 'conduct of a sexual nature was so
> pervasive...that it can reasonably be said that such conduct created a
> hostile or offensive work environment which affected the motivation and
> work performance of those who found such conduct repugnant and
> offensive,' [Judge] Pratt said."

Good  - so at least we can establish that basics that we can agree on.
Where I seem to differ from you is that it seems clear from the record
of the Broderick case that the Judge concluded that it met the
reasonable woman standard of what kind of environment would be deemed
hostile is because of the specific verbal and physical behavior that
occurred in the office. In the Broderick case, not only had she been
subject to sexual come on's (you are right this was minimal compared
to the other events going on, but it was an important part of making
her case), but she was able to show that there was pervasive sexual
behavior and comments about the sexual behavior in the workplace. She
was also able to show that she was disadvantaged by not participating
in the either the behavior or the conversation about the behavior. In
Scovell's case, by her own report, nobody came on to her, she never
suffered any workplace disadvantage, and there was no overt sexual
behavior or discussion about the sexual behavior in the workplace. In
other words, Broderick could not avoid the sexual behavior of
co-workers and supervisors, because it was carried out at work, and
talked about. This is what made it pervasive, and this is what
convinced the judge that a reasonable woman would find it hostile.
Scovile, OTOH, says she knew from rumors and common knowledge that
sexual behavior was going on, but does not report actual sexual
behavior in the workplace, or frequent conversations or comments about
it, and the sexual behavior and comments were not pervasive (except
perhaps in her own imagination). Now, perhaps Scoville has not
revealed all of the facts, and she really did experience a pervasive
exposure to sexually related behaviors and comments of coworkers and
their supervisors. If she adds to her story, and those additions are
supported by appropriate evidence, then we would be talking about
something different.

There is no doubt in my mind that Broderick was exposed to a hostile
work environment. One area where we seem to disagree is that you think
the workplace that Scoville describes meets the Broderick standard - I
don't think it even comes close. This may be related to what seems
like a second area were we disagree; an environment in which
colleagues and bosses are sleeping with each other does not
constitute, ipso facto a hostile work environment. To support the
claim of a HWE, an employee has to do more than simply demonstrate
that supervisors are sleeping with employees, and assert that this
makes them feel uncomfortable. That employee would have to demonstrate
that these sexual behaviors had some kind of pervasive influence on
the working environment of the employee (other than simply the
employee's disapproval).

To make this more TV related: Angela may not approve of Jim sleeping
with Pam, but her disapproval alone is not sufficient to support a
claim of a HWE. If Jim started joking about Pam's sexual attributes or
talents, or commented on them in the course of business, or had sex
with Pam in the break room, or suggested that Angela would have a
better chance of advancement if she loosened up and had sex more like
Pam, then she might have a claim.

However, note that a paper company is different than a late night
comedy program. A judge is likely to give significantly more leeway to
sexually suggestive humorous comments in the workplace of a late night
comedy show than to those in a paper company.

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