When a Human Resources ­professional brings a discrimination claim, his former employer will be on high alert. But the recently decided case, Grdinich v. Philadelphia Housing Authority, No. 16-03070, 2017 U.S. Dist. LEXIS 74892 (E.D. Pa. May 17) (Pappert, J.), raises the question of whether every discussion by an HR professional in the workplace rises to the level of ­”protected activity” under the anti-discrimination laws.

EEO Officer Discusses Complaints With Supervisor

Rosanna Grdinich was the Equal Employment Opportunity officer for the Housing Authority from approximately 1999 to 2008. She was responsible for fielding and investigating discrimination complaints from Philadelphia Housing Authority (PHA) employees. As part of Grdinich’s job, in late summer, early fall 2008, she advised one of her supervisors, Carl Greene, that he was the subject of three anonymous phone complaints of harassment. Grdinich claims that Greene did not respond, but rather simply walked away from her and that this was the last direct communication that she had with him ­during her employment. Grdinich never opened an investigation into the anonymous calls because she subsequently learned that none of the three women were still employed by 
the PHA.

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