The Court of Appeals for Hamilton County recently dismissed a plaintiff’s sex discrimination hostile work environment claim because the plaintiff had voluntarily returned to her job after quitting it. Garrison v. Nippert, et al., Hamilton App. No. C-120384, 2013-Ohio-1965 (May 15, 2013).
Plaintiff Garrison alleged that immediately upon beginning her employment with Defendant Nippert, she was subjected to repeated sexual harassment — lewd sexual remarks and unwanted touching. Ultimately reaching her “breaking point,” the plaintiff resigned. However, weeks later, the plaintiff returned to work for Defendant Nippert because she was “desperate for money.”
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Labor & Employment Developments 