Resistance to Management Style Didn’t Create Hostile Work Environment, Court Finds
•February 13, 2026
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Why It Matters
The decision clarifies the evidentiary burden for hostile‑work‑environment claims and underscores the importance of clear supervisory policies in higher‑education institutions.
Key Takeaways
- •Court ruled resistance stemmed from management style, not discrimination.
- •Drexel failed to clearly communicate supervisory expectations.
- •Executive's hostile‑work‑environment claim dismissed under severe standard.
- •IA head received verbal warning, then removed from supervision.
- •Separate ADA lawsuit dismissed after plaintiff missed deadline.
Pulse Analysis
The Drexel University case highlights how U.S. courts continue to apply a strict “severe or pervasive” threshold when evaluating hostile‑work‑environment claims under Title VII and Section 1981. In *Gunter v. Drexel University*, the judge concluded that the internal audit chief’s objections to increased oversight were ordinary managerial disagreements, not discriminatory microaggressions. By emphasizing the absence of slurs, intimidation, or conduct tied to race or sex, the ruling reinforces that plaintiffs must demonstrate clear, animus‑driven behavior to survive summary judgment. This standard remains a pivotal gatekeeper for employment‑law litigation across corporate and academic settings.
The factual backdrop—an executive who favored hands‑on supervision clashing with a department head accustomed to autonomy—underscores the operational risks when organizations shift leadership styles without transparent communication. Drexel’s own admission of poor expectation‑setting suggests that even well‑intentioned policy changes can generate friction, yet the court held that such friction alone does not constitute a hostile environment. Universities and large enterprises should therefore codify supervisory protocols, document performance expectations, and train managers to differentiate constructive feedback from unlawful discrimination, thereby limiting exposure to costly lawsuits.
Beyond the immediate verdict, the case sends a cautionary signal to compliance and audit functions, where independence is often prized. Executives must balance oversight with preserving functional autonomy to avoid perceptions of interference. Moreover, the dismissal of the plaintiff’s separate ADA claim—due to a missed filing deadline—illustrates how procedural missteps can be fatal, regardless of substantive merit. Together, these outcomes stress the dual importance of substantive legal standards and diligent case management for any organization navigating complex employment regulations.
Resistance to management style didn’t create hostile work environment, court finds
A federal district court in eastern Pennsylvania backed Philadelphia‑based Drexel University’s argument that a White male direct report resisted being supervised by a Black compliance executive because of her management style—not because of her race, color, or sex—according to a Feb. 9 ruling in Gunter v. Drexel University.
Notably, “not all the blame lies with [the White male]. Drexel did a poor job of communicating its expectations to [him] and making sure that he adhered to those expectations,” the court observed.
Drexel and the executive’s attorney did not respond to requests for comment.
The executive served as vice president and chief compliance, privacy, and internal audit (IA) officer. She was responsible for administrative management of the IA department and the White male because he was head of the IA department.
Her predecessor, also a White male, gave the IA head wide berth in running the department. He preferred “staying in [his] lane,” according to court documents, confining his role to tasks such as reviewing and approving time sheets and budgets and having limited interaction with the IA head and IA employees.
By contrast, the executive took a “more involved approach.” She liked to have one‑on‑one meetings with the IA head and his staff and to participate in his hiring decisions, the record showed.
She believed the IA head discriminated against her due to her race and sex because, unlike with her predecessor, he was resistant to her supervision. As examples, she said he excluded her from a job interview for his second‑in‑command, asked her to run things by him before making announcements to his staff, and repeatedly objected to other actions, such as when she asked him to help her update the department’s website.
For his part, he believed she was interfering with his authority over IA operations and compromising IA’s independence, according to court records. Drexel’s chief operating officer, who is White, assured him this was not the case and issued him a verbal warning for being disrespectful.
After about three years, the executive complained to HR that his behavior was discriminatory and harassing. An outside attorney investigated and concluded he wasn’t engaging in race‑ or gender‑based discrimination or harassment. The COO then removed him from the executive’s supervision.
The executive later sued Drexel for allegedly violating Section 1981 of the Civil Rights Act of 1866 and Title VII of the Civil Rights Act of 1964 by subjecting her to a race‑ and sex‑based hostile work environment. Following a three‑day bench trial, the court granted judgment to Drexel.
“To go from having near‑total autonomy over a department to having to report to a supervisor who expected updates, deliverables, and communication would not be easy,” and the IA department head “struggled mightily” with the change, the court pointed out.
However, his responses were not discriminatory microaggressions, but rather “innocent workplace misunderstandings,” the court found.
The court explained that, to the extent some responses may have been microaggressions—such as when he allegedly complained to the executive about her tone and asked her to stop arguing—she failed to demonstrate the remarks resulted from race‑ or gender‑based animus.
Importantly, the court said the IA head used no slurs and didn’t engage in intimidating conduct, and there was no evidence he physically threatened or humiliated the executive.
While his behavior may have made him difficult to work with and possibly insubordinate, the executive’s claim failed because, under the required “severe or pervasive” standard, it would not have created an abusive working environment for a reasonable person in similar circumstances, the court held.
The same plaintiff in Gunter v. Drexel University filed a different lawsuit last year alleging the institution also violated the Americans with Disabilities Act by not accommodating her PTSD when it required her to attend a Zoom meeting. That case was eventually dismissed by the judge after the plaintiff missed a deadline.
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