Great Lakes Wire

If a supervisor yells at an employee or throws a notebook during a disagreement, this behavior may not meet the legal standard for a hostile work environment. In the case of Brooks v. Grundmann, the U.S. Court of Appeals for the D.C. Circuit determined that such actions were considered an “isolated expression of frustration,” and did not qualify as unlawful harassment under Title VII of the Civil Rights Act of 1964.

Patricia Brooks alleged that her supervisor created a hostile work environment from 2005 to 2008 by yelling at her, insulting her in front of colleagues, and throwing a notebook toward her during a project dispute. The court dismissed the case, finding that these incidents were not “severe or pervasive” enough to meet the legal threshold for harassment. The court also noted that while management could have been better, the supervisor addressed legitimate performance issues appropriately.

A similar outcome was reached in Fichter v. AMG Resources Corporation. Shirley Fichter claimed gender discrimination and termination due to a hostile work environment after being asked by her manager to work closer to home, delegate tasks, complete assignments more quickly, and follow attendance and vacation procedures. The court found these requests fell within normal management expectations rather than constituting unlawful harassment.

For workplace conduct to be classified as creating a hostile environment under federal law, it must be linked to a protected characteristic such as race, sex, religion, age, or disability. Additionally, it must be severe or pervasive enough to create abusive or intimidating conditions and satisfy both subjective (the employee feels harassed) and objective (a reasonable person would feel harassed) standards.

Minor annoyances or isolated outbursts usually do not reach this threshold. However, human resources professionals are encouraged to address poor management practices proactively through training in respectful communication and feedback, early reporting mechanisms for inappropriate conduct, documentation of behavioral patterns rather than single events, and intervention when low morale is detected—even if no legal violation has occurred.

According to Linda Olejniczak from ASE: “Not all bad management is unlawful harassment. But if ignored, it can erode trust, fuel turnover, and damage culture. All risks HR can’t afford to overlook.”