Rolfs v. Home Depot U.S.A., Inc., 971 F. Supp. 2d 197 (2013)

Citation: Rolfs v. Home Depot U.S.A., Inc., 971 F. Supp. 2d 197 (2013)
Parent Document: Rolfs v. Home Depot U.S.A., Inc., 971 F. Supp. 2d 197 (2013)
Jurisdiction: New Hampshire (state)
Effective Date: 2013-09-20
Original Source: https://www.courtlistener.com/opinion/8728300/rolfs-v-home-depot-usa-inc/ ↗

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That a series of minor retaliatory actions may, when considered in the aggregate, satisfy the McDonnell Douglas prima facie “adverse action” requirement, is settled law in this Circuit. See, e.g., Noviello [u City of Boston], 398 F.3d [76,] 91 [ (1st Cir.2005) ] (holding that “subjecting an employee to a hostile work environment in retaliation for protected activity constitutes an adverse employment action”); see also Billings v. Toum of Grafton, 515 F.3d 39, 54 n. 13 (1st Cir.2008). But, as the third prima facie factor commands, it is similarly accepted that alleged retaliatory actions against an employee must bear a causal connection to some protected conduct in order to establish a prima facie claim that rests on a hostile work environment theory. Consequently, “[i]t is only those actions, directed at a complainant, that stem from a retaliatory animus which may be factored into the hostile work environment calculus.” Noviello, 398 F.3d at 93.

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