10th Circuit: Supervisor’s Uncomfortable Conduct Doesn’t Equal Hostile Environment

(November 4, 2015, 2:19 PM EST) -- DENVER — A district court’s finding that a supervisor’s conduct may have made people uncomfortable doesn’t mean that the court erred in denying a subordinate’s hostile work environment claim, the 10th Circuit U.S. Court of Appeals ruled Oct. 30 (Bryan McElroy v. American Family Insurance, a/k/a American Family Insurance Group, No. 14-4134, 10th Cir.; 2015 U.S. App. LEXIS 18904).

(Order and judgment available. Document #73-151106-012R.)

Bryan McElroy worked for American Family Insurance (AFI) for more than a decade before he experienced what he called a “bad...
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