September 2022 - Parks & Recreation - 35

determine " whether Defendant's conduct
included repeated abusive discriminatory
comments or treatment. "
Relevant Actions
In determining whether " Defendant's
conduct might have dissuaded
a reasonable worker from making
a charge of discrimination, " the
federal district court acknowledged
" a hostile work environment cannot
be said to occur on any particular
day. " On the contrary, the court
would consider " the entire time period
of the hostile environment " if
" at least one act contributing to the
hostile-work-environment
claim
occurred within the filing period. "
In this particular case, the court
would, therefore, consider actions
that took place before March 31,
2016, if those acts were " sufficiently
related to those incidents occurring
within the [300-day] statutory
period as to form one continuous
hostile work environment. "
Because the federal district court
already had ruled certain acts
were " not retaliatory, " Defendant
claimed the court should not consider
three actions that occurred
after March 31, 2016: (1) Odom's
supervision of Plaintiff starting in
April 2016; (2) Lynch's September
2016 written reprimand; and (3) the
January 2017 transfer of Benson,
Plaintiff's assistant. The federal district
court rejected this argument.
In the opinion of the court,
these non-retaliatory actions from
June 2013 through January 2017
were still " relevant to determining
whether Defendant's conduct
might have dissuaded a reasonable
worker from pursuing a discrimination
charge " :
Even where one employment action
may not rise to the level of an
adverse action, multiple incidents
taken together might dissuade a
reasonable worker from making
or supporting a discrimination
charge....
Furthermore, the existence
of an extended period of
time where few (or no) hostile acts
take place does not prevent actions
occurring before and after that
time period from being part of the
same hostile work environment.
As a result, the court would consider
all acts predating March 31,
2016, as part of the alleged hostile
work environment, " as long as
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35

September 2022 - Parks & Recreation

Table of Contents for the Digital Edition of September 2022 - Parks & Recreation

September 2022 - Parks & Recreation - Intro
September 2022 - Parks & Recreation - Cover1
September 2022 - Parks & Recreation - Cover2
September 2022 - Parks & Recreation - 1
September 2022 - Parks & Recreation - 2
September 2022 - Parks & Recreation - 3
September 2022 - Parks & Recreation - 4
September 2022 - Parks & Recreation - 5
September 2022 - Parks & Recreation - 6
September 2022 - Parks & Recreation - 7
September 2022 - Parks & Recreation - 8
September 2022 - Parks & Recreation - 9
September 2022 - Parks & Recreation - 10
September 2022 - Parks & Recreation - 10a
September 2022 - Parks & Recreation - 10b
September 2022 - Parks & Recreation - 11
September 2022 - Parks & Recreation - 12
September 2022 - Parks & Recreation - 13
September 2022 - Parks & Recreation - 14
September 2022 - Parks & Recreation - 15
September 2022 - Parks & Recreation - 16
September 2022 - Parks & Recreation - 17
September 2022 - Parks & Recreation - 18
September 2022 - Parks & Recreation - 19
September 2022 - Parks & Recreation - 20
September 2022 - Parks & Recreation - 21
September 2022 - Parks & Recreation - 22
September 2022 - Parks & Recreation - 23
September 2022 - Parks & Recreation - 24
September 2022 - Parks & Recreation - 25
September 2022 - Parks & Recreation - 26
September 2022 - Parks & Recreation - 27
September 2022 - Parks & Recreation - 28
September 2022 - Parks & Recreation - 29
September 2022 - Parks & Recreation - 30
September 2022 - Parks & Recreation - 31
September 2022 - Parks & Recreation - 32
September 2022 - Parks & Recreation - 33
September 2022 - Parks & Recreation - 34
September 2022 - Parks & Recreation - 35
September 2022 - Parks & Recreation - 36
September 2022 - Parks & Recreation - 37
September 2022 - Parks & Recreation - 38
September 2022 - Parks & Recreation - 39
September 2022 - Parks & Recreation - 40
September 2022 - Parks & Recreation - 41
September 2022 - Parks & Recreation - 42
September 2022 - Parks & Recreation - 43
September 2022 - Parks & Recreation - 44
September 2022 - Parks & Recreation - 45
September 2022 - Parks & Recreation - 46
September 2022 - Parks & Recreation - 47
September 2022 - Parks & Recreation - 48
September 2022 - Parks & Recreation - 49
September 2022 - Parks & Recreation - 50
September 2022 - Parks & Recreation - 51
September 2022 - Parks & Recreation - 52
September 2022 - Parks & Recreation - 53
September 2022 - Parks & Recreation - 54
September 2022 - Parks & Recreation - 55
September 2022 - Parks & Recreation - 56
September 2022 - Parks & Recreation - 57
September 2022 - Parks & Recreation - 58
September 2022 - Parks & Recreation - 59
September 2022 - Parks & Recreation - 60
September 2022 - Parks & Recreation - 61
September 2022 - Parks & Recreation - 62
September 2022 - Parks & Recreation - 63
September 2022 - Parks & Recreation - 64
September 2022 - Parks & Recreation - Cover3
September 2022 - Parks & Recreation - Cover4
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/september-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/august-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/july-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/june-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/may-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/april-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/march-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/february-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/january-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/december-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/november-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/october-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/september-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/august-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/july-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/june-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/may-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/april-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/march-2021
https://www.nxtbookmedia.com