A female employee of Avis Rent A Car failed to prove that she had been subjected to sexual harassment or sex bias, ruled the Eighth Circuit Court of Appeals.

The employee claimed that she endured a hostile work environment due to the conduct of her supervisor who allegedly kicked her desk and generally engaged in loud, rude behavior.

The Eighth Circuit noted that the supervisor's disruptive behavior was directed at both sexes. Additionally, the conduct was not severe or pervasive enough to alter the terms of her employment and Avis had exercised reasonable care to stop the harassment from occurring.

The employee also failed to show that she was terminated in retaliation for complaining about her supervisor's conduct. Even if her complaints were considered a protected activity under Title VII, said the circuit court, the employee failed to show a causal connection between those events and her termination.  

Sharon Hesse v. Avis Rent A Car System, Inc., decided 1/10/05