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Bad Breakup Fails to Meet Sex Harassment Standard

Caitlin Dole and Craig Sleurs worked as patrol officers in the town of Bethlehem. They also dated for about four months. Ms. Dole ended the relationship but Mr. Sleurs was not too happy about it. He sent her threatening text messages, voicemails, and Facebook messages.

Mr. Sleurs left a series of hostile messages that included explicit language. The next day, he apologized. However, he then publicly posted a similar tirade about her. Ms. Dole became  “concerned” and she was afraid he might become violent. She did not report it. However, her father reported it to a lieutenant. When the lieutenant approached Ms. Dole about Mr. Sleurs’ behavior, she purportedly said she did not want to file a complaint. Ms. Dole has disputed that assertion. The department did tell Mr. Sleurs to cease contact with her. Ms. Dole still felt that he was harassing her and resigned her employment; the parties disputed the nature of her stated reason for leaving. Nevertheless, she filed suit for sexual harassment.

The New York district court dismissed Ms. Dole’s sexual harassment claim, finding that Mr. Sleurs behavior was not based on her gender.

“The unwelcome voicemails, text messages, and Facebook posts express anger and frustration that Plaintiff ended their relationship and refused to communicate with him. They also suggest that [he] hoped that they could resume the relationship. None of his communications, however, permit the inference that his harassment … was motivated by her sex.”

Moreover, the court noted that even if the conduct had been based on her gender, it was not sufficient severe or pervasive to establish a hostile work environment action.