Ivan v. County of Middlesex

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• explaining that “[n]ot all words that have some sexual connotation constitute discrimination because of sex. Courts have held that the word ‘bitch’ is not necessarily sexual in nature.”
• finding punitive damages claim could survive summary judgment where there was evidence upper management ignored a recommendation to impose punishment on harasser
• finding “a significant number of incidents occurring over the course of four years” to be pervasive
• explaining that in considering cumulative effect, a court must keep in mind “‘that each successive episode has its predecessors, that the impact of the separate incidents may accumulate, and that the work environment created may exceed the sum of the individual episodes’”
• “When an act is done by a supervisor its severity may be exacerbated because the supervisor has a unique role in shaping the work environment.”
• “The [NJLAD] does not impose individual liability upon non-supervisory employees, but a supervisor may be liable for aiding and abetting his or her own conduct.”

Source: CourtListener parenthetical corpus (CC0).