U.S. District Court, WDNY
Nondiscriminatory Reason for Suspension — Employer’s Criticism
Lynch v. National Fuel Gas Distribution Corporation
Background: The plaintiff commenced a gender-discrimination and retaliation suite against her former employer. The plaintiff was terminated after an investigation into the discrepancies in her timesheets, as well as failure to conduct a proper investigation in conformity with the defendant’s practices and procedures. The defendant moved for summary judgment.
Ruling: The District Court granted the defendant’s motion. The court noted that a supervisor’s mere criticism of her work, even when loud and belittling, does not fall necessitate a hostile work environment, unless it is severe and pervasive. Further, the plaintiff did not rebut the defendant’s nondiscriminatory reason for her suspension and termination.
Mary M. Lynch, pro se; Melinda G. Disare and Michael E. Hickey of Jaeckle Fleischmann & Mugel for the defendant