BOISE – A longtime state worker who quit amid claims her boss showed favoritism to another employee and created a hostile work environment is not entitled to sue for damages, the Idaho Supreme Court ruled this week.
Lynette Patterson alleges that she and other employees in her unit at the state Department of Health and Welfare were negatively impacted by the favoritism their boss showed to another employee. Patterson was program supervisor in the fraud unit at the state agency.
Patterson claims her boss at the state agency, Audits and Investigations Bureau Chief Mond Warren, had a relationship with another female employee and that resulted in more favorable treatment toward that employee.
But the justices ruled unanimously Wednesday that the alleged conduct was not sufficient to constitute a hostile work environment under state and federal civil rights laws. The Idaho Statesman reports the ruling was the Idaho Supreme Court’s first decision on so-called “paramour favoritism.”
Patterson quit her job in 2007 after 25 years with the state.
“What her allegations boil down to, in essence, is that her supervisor had a relationship with a lateral employee, resulting in more favorable treatment for the paramour and her unit,” Justice Jim Jones wrote in the court’s decision.
The court upheld the earlier decision of 4th District Judge Michael McLaughlin, who previously dismissed Patterson’s claims against the state.
Patterson said she was forced to quit her job due to her complaints about the office romance. Patterson first made a complaint in fall 2004 and Warren denied the relationship.
Several months later, he acknowledged he had an intimate relationship with the woman five years earlier, according to the high court ruling. The relationship was said to have lasted one year, with sporadic intimate encounters thereafter, Jones wrote.
The state agency investigated Patterson’s allegations that the female employee received preferential treatment, including better pay and equipment. An investigation found Warren and the employee had engaged in a romantic relationship but there was no evidence to support Patterson’s allegations, the ruling said.
Patterson quit in March 2007 after she received a draft of a performance evaluation that found she did not “achieve performance standards.”
“I can no longer work under these conditions,” Patterson said in her resignation letter. “The work environment has become increasingly hostile over the past few years. Retaliation is becoming unbearable. For health concerns and my own peace of mind, I am resigning.”