environment is too
hostile for Mrs.
Larkins to dare
set foot in the
|The Nature of the Unwanted Acts
(1) “The nature of the unwelcome acts.”
The actions taken against Mrs. Larkins by Mr. Werlin were
extremely serious. He participated in and encouraged serious
false allegations, which escalated and increased in number, and he
removed her from her classroom twice based on false allegations.
Mrs. Larkins could not safely return to work.
(2) “The frequency of the offensive encounters.”
The hostile acts were remarkable in their frequency. After the first
action taken against Petitioner on February 12, the second event
occurred after only one week back at work. This is a very high
level of frequency for being taken out of one’s classroom on
charges that the district now claims have nothing to do with this
dismissal. They have everything to do with why Petitioner was
afraid to go back to work.
(3) “The total number of days over which all the offensive
To this day the District has never investigated or retracted the
allegations that Petitioner was going to kill teachers. At this time
the belief among many teachers in the District is that Mrs. Larkins
might come to school and shoot them all. This work environment is
too hostile for Mrs. Larkins to dare set foot in the district.
(4) “The context in which any offensive conduct occurred.”
The context was a campaign by Mr. Werlin to destroy Mrs. Larkins’
career. The evidence is overwhelming that he slandered her to
teachers and the principal of Castle Park Elementary School, and
solicited allegations against her, and promised her accusers that
they would never have to face the accused.
The environment was hostile because Mrs. Larkins was refused
protection of the contract; CVE wouldn’t arbitrate although it
admitted it was wrong for Mr. Werlin to handle grievances against
himself; and Werlin had total personal, arbitrary control over Mrs.
Larkins, including the ability to make absolutely any allegation
about her and act on it, with no oversight by Superintendent or
On page 865 of the Court Reporter’s transcript, Mrs. Larkins’
counsel explained that the “hostile environment” concept was not
being used in this case as a “sword,” a complaint used to establish
liability of the employer, but as a defense against a charge filed by