News

• DOI: http://doi.org/10.1002/nba.30384
• Published date: 01 November 2017
• Date: 01 November 2017

12

NOVEMBER 2017NONPROFIT BUSINESS ADVISOR

© 2017 Wiley Periodicals, Inc., A Wiley Company • All rights reserved

DOI: 10.1002/nba

EMPLOYMENT LAW (continued from page 11)

News

that the Title VII prohibition of harassment on

the basis of sex required neither asexuality nor

androgyny in the workplace. He explained that

it forbid only behavior so objectively offensive as

to alter the conditions of employment. He ruled

that Hobson’s alleged conduct was not severe or

pervasive enough to create an environment that a

reasonable person would nd hostile or abusive or

prohibited by the statute.

EMPLOYER WINS ➔ Judge Lemelle was not

impressed with Malin’s allegations. He said that

courts had ruled in much more egregious cases

that the alleged harassment was not sufciently

severe or pervasive to create an objectively hostile

or abusive work environment. He explained that

Hobson was not accused of such egregious conduct

as showing employees nude videos or nude images.

The judge also cited as an example a specic case

where the plaintiff lost even after alleging that a

supervisor had grabbed her buttocks and made

suggestive comments.

With respect to the issue of whether Malin had

personally been offended, the judge ruled that it

was not reasonable that she actually believed that

Hobson’s romantic commentary created a sexually

hostile work environment in a way that was action-

able under Title VII.

Judge Lemelle dismissed the suit, ruling that

the instances alleged by Malin could not create a

sexually hostile environment in a legally cognizable

manner.

[Malin v. Orleans Parish Communications Dis-

trict, U.S. District Court for the Eastern District

of Louisiana, No. 16-16465, 06/05/17]. ■

Giving rises in Africa,

falls elsewhere

Giving in Africa has risen over the last year, even

while giving more broadly has fallen, according to

the Charities Aid Foundation World Giving Index.

The index records the number of people who

helped a stranger in the past month, volunteered

their time or gave money to a good cause. For the

2017 report, 146,000 people were interviewed in

139 countries.

This year, the global index was down slightly

from 2016. Donating money and helping a stranger

were down 1.8 percentage points, while volunteer-

ing was down 0.8 percentage points, the index

showed.

But while many developed nations fell—includ-

ing the United States, the United Kingdom and

Australia—Africa showed the strong performance

it saw in 2016, experiencing growth across all three

giving behaviors. It was the only continent to

achieve this, the CAF said.

Four of this year’s top 20 places were held by

African nations (Kenya, Sierra Leone, Liberia and

Zambia), and eight African countries (Ghana,

Zambia, Sierra Leone, Kenya, Liberia, Zimbabwe,

South Africa and Tunisia) saw their World Giving

Index score increase by more than ve percentage

Salvation Army appoints

new national leaders

The Salvation Army has appointed David and

Sharron Hudson to serve as the national com-

mander and national president of women’s min-

istries for the Salvation Army USA, respectively.

The Hudsons will ll the void left by David and

Barbara Jeffrey, who have retired after serving a

combined 96 years as Salvation Army ofcers, the

organization said.

In his new role, David Hudson will lead a net-

work of 3,559 ofcers, 65,469 employees and 3.2

million volunteers serving in more than 7,500 cen-

ters of operation throughout the United States. He

will also act as chairman of the national board of

trustees and will be responsible for presiding over

triannual conferences, which bring together the

key executive leaders of the Salvation Army’s four

territories in the United States.

Sharron Hudson will work alongside leaders of

the four territories in the United States to lead the

Salvation Army’s Women’s Ministries, which work to

empower and equip women in all facets of life. ■

points. Africa accounted for most of the countries

on this year’s “most improved” list, the CAF said.

For more information, visit http://bit.ly/2xo6L54.