Employees will often complain that their workplace is “hostile” because their supervisor is critical of their work performance. But, of course, there is a difference between a “critical” work environment and a legally actionable ”hostile” environment. This distinction was made clear in the recent decision of Carter v. Vanguard Group, No. 15-05370, 2016 U.S. Dist. LEXIS 97512 (E.D. Pa. July 26, 2016).
Cassandra Ballard-Carter was hired by Vanguard as a processing associate in 1996 and, in 2007, became a client relationship administrator (CRA). A CRA’s job is to be responsible for running a client’s retirement plan on a day-to-day basis. As a CRA, Ballard-Carter was responsible for working directly with the client and in tandem with a client relationship manager. The CRM, however, is responsible for the overall client relationship. Both the CRM and CRA report to the client administration manager.
Issues Noted With Performance
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