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The Employer Handbook Blog
She Said Don’t Call Me “Sweetheart.” That Still Wasn’t Enough to Sue.
Gendered nicknames may be unprofessional, but that doesn’t make them unlawful. A recent federal court decision explains why even repeated comments like “sweetheart” may fall short of what Title VII prohibits.
TL;DR:
A manager repeatedly called an employee “sweetheart.” She objected, complained, and was later fired. But a court said that wasn’t enough for either a hostile work environment or retaliation claim.
She objected to being called “sweetheart.” The court still dismissed her case.
A former PR director alleged that her male manager began calling her “sweetheart” once or twice a week. She told him to stop. He didn’t.
She said she later complained about the term and was eventually fired. She brought a lawsuit claiming hostile work environment and retaliation under Title VII.
The court dismissed both claims.
The hostile work environment claim didn’t meet the legal threshold
To bring a hostile work environment claim under Title VII, a plaintiff must allege:
- Unwelcome conduct
- Based on a protected characteristic (like sex)
- That is severe or pervasive enough to alter the terms or conditions of employment
At the motion to dismiss stage, the bar is relatively low—but courts still require more than occasional, mildly offensive remarks. Here, the court found that while the term “sweetheart” was gendered and unwelcome, using it once or twice a week over a few months—without allegations of disruption, humiliation, or escalation—wasn’t enough.
To drive the point home, the court cited other decisions where even more offensive or profane language failed to qualify. One involved a supervisor repeatedly using a vulgar, gender-based insult. Others involved repeated use of terms like “babe,” “doll,” and “honey.” In each case, the courts concluded the behavior didn’t rise to the level of a hostile work environment under Title VII.
This court reached the same conclusion.
Complaining about “sweetheart” didn’t amount to protected activity
To state a retaliation claim, the employee must have opposed a practice they reasonably believed was unlawful under Title VII.
Here, the court held that the plaintiff’s complaint—asking her manager to stop calling her “sweetheart”—did not reflect an objectively reasonable belief that she was reporting unlawful discrimination. In fact, the court had already concluded that the nickname didn’t amount to a hostile work environment.
Because the underlying conduct wasn’t plausibly unlawful, objecting to it wasn’t protected activity under Title VII. And without protected activity, there’s no retaliation claim.
Two takeaways for employers and HR
✅ Title VII isn’t a civility code. Hostile work environment claims require more than occasional rude or condescending comments. Courts expect a pattern of severe, humiliating, or disruptive conduct—not just unprofessional or outdated language. “Sweetheart” may violate internal expectations, but that doesn’t automatically make it illegal.
✅ Not all complaints are legally protected—but they can still flag bigger risks. Comments like “sweetheart,” “honey,” or “sweetie” may not, on their own, violate Title VII or trigger retaliation protections. But they often don’t happen in isolation. They can signal broader workplace dynamics that, taken together, could create legal exposure. Even if a complaint isn’t protected activity under the law, it still warrants a thoughtful, documented response.
Bottom line
Telling someone to stop calling you “sweetheart” is a perfectly reasonable workplace boundary. But unless the conduct is more serious, more frequent, or clearly discriminatory, objecting to it may not give rise to legal claims under Title VII. Still, employers should make sure this kind of behavior is addressed promptly through training, clear expectations, or disciplinary action—before it becomes part of a bigger problem.