8th Circuit: No Hostile Environment Where Employee Doesn’t File Any Complaints

Mealey's (September 5, 2017, 12:42 PM EDT) -- ST. LOUIS — An employee who exchanged “I love yous” with her superior and occasionally touched him in a platonic manner and failed to file any complaints about his conduct creating a hostile work environment until she filed a federal complaint against her employer after she resigned cannot now prove a hostile work environment claim, an Eighth Circuit U.S. Court of Appeals panel ruled Aug. 31 (Bobbette M. Blake v. MJ Optical, Inc., No. 16-3100, 8th Cir., 2017 U.S. App. LEXIS 16742)....