A federal district court in Alabama granted an employer’s motion for summary judgment regarding a former general manager’s hostile work environment claims.  Thrower v. Yedla Management Co. Plaintiff, a Caucasian female, alleged that during her employment, the Purchasing Manager mistreated her on the basis of gender and race, creating a hostile work environment by excessively questioning her decisions and yelling and cursing at her.  She made complaints to her superior but alleges no action was taken.  Six months into her employment, she was terminated.

Plaintiff was unable to offer any evidence that she was mistreated due to her race or gender.  The record established that her manager treated virtually all coworkers unpleasantly.  As the court noted, “Title VII was never intended to protect employees from all unpleasant and rude conduct in the workplace.”  Because Plaintiff could not establish that male or non-white employees were treated more favorably, the hostile work environment claim was dismissed.

The evidence in this case showed that the manager did not treat Plaintiff differently due to her gender or race.  However, employers should not ignore “equal opportunity harassers.”  Such behavior leads to disgruntled employees who likely will assert claims that employers necessarily have to defend at great expense.