‘Less Than Utopian’ Working Conditions Not Necessarily Race Discrimination

Angela Sykes is a police communications officer who works for the Pennsylvania State Police. She is the only black female employee at the Washington, Pennsylvania station. Sykes filed a lawsuit against her supervisor and the State Police alleging that she was the victim of a racially hostile work environment.

The federal Third Circuit Court of Appeals dismissed Sykes’ lawsuit. The Court observed that there was a difference between a workplace that was simply a bad working environment and a legally-recognized “hostile work environment.” As the Court phrased it, “there is no dispute that, for whatever reason, there was friction and tension in Sykes’ workplace. There is also no dispute that Sykes complained of numerous slights and wrongs, real or perceived, which, rightly or wrongly, caused or fueled the friction and tension. We recognize that the general atmosphere in which Sykes worked was less than Utopian, but we find the record devoid of evidence that any differences in treatment were motivated by racial bias.”

Sykes v. Pennsylvania State Police, 2008 WL 901969 (3rd Cir. 2008).

This article appears in the July 2008 issue