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Chesier v. On Q Financial Incorporated deals with the concept of a hostile work environment. Chesier, the defendant, worked for On Q and fulfilled administrative functions. One day, her work-related conversation with Middleton, her supervisor, suddenly took a sexual direction. Both spent around three hours sending and receiving messages with sexually explicit content, and Chesier did not attempt to stop the conversation.
One day after, Chesier filed a lawsuit against On Q, claiming that she had suffered from a hostile work environment, and Middleton lost his job. Despite regarding Middleton’s behavior as ethically inappropriate due to the power differential between the involved parties, the court declined Chesier’s claim and denied her motion for summary judgment. It held that Middleton’s conduct was not severe enough to constitute a hostile working environment.
The court’s decision could have different effects on the involved parties and society in general. Firstly, the decision offers some protection for organizations by preventing single and non-systematic incidents of sexual harassment from inflicting responsibility on entire companies. It does so by requiring Chesier to prove that the experience was extremely severe. To qualify as such, Middleton’s conduct would have to involve measurable negative consequences for Chesier’s physical or mental health, for instance, injuries or moral damage from intimidation or unwanted touching. None of these outcomes were stated and proven by the defendant.
Finally, the decision can prevent accusations against organizations that do not leave the reported incidents of harassment unaddressed, thus protecting responsible employers. Chesier’s claim involved no evidence that On Q had been explicitly supportive of Middleton’s behaviors or failed to react accordingly. Instead, right after receiving the plaintiff’s complaint, On Q initiated an internal investigation and then fired Chesier’s supervisor, thus removing the key source of concern for the employee. Considering that, the abovementioned case outcomes further differentiate between organizations that actually take steps to prevent further incidents and employers that are aware of workers’ or contractors’ misconduct and fail to intervene.
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