Situation: A manager yells at an employee in front of others. Is this workplace bullying?

As good HR professionals, we do have to ask the investigative questions as to what surrounded the yelling, and how the employee defines "yelling". But there is never a time that yelling is appropriate unless it is to clear a building during a disaster - and even then, a more calming approach is best.
But I agree with Ms. Din - bullying does not have to be just in the context of yelling. There are managers, directors and VP's out there that are much schooled in bullying by the tone they use in meetings, on phone calls, in emails, etc. Frankly, these are the most dangerous leaders because they have been doing it for so long and are so schooled in the behavior that they build nothing but fear in the organization - and usually are feared by their peers and even their own managers. HR needs to take a deep look at retaining these managers vs. the destruction they rack on the organization’s ability to grow, attract and retain top talent.
Some states - including Illinois - are seeking to include bullying as part of the Harassment Policy. When looked at, bullying is already defined within that practice. Even if it is never enacted as law, why would we want to tolerate the behavior within our organization? Federal mandates and laws often (not always!) come about because we fail to provide and require sound management principles.

Yes it is bullying but more importantly it shows a gross lack of respect for the individual and all those around them. It also shows a lack of self restraint. I have been a supervisor and manager for over 35 years. In all that time, I never chewed an employee out in public no matter how angry I have been. When really hot, I excuse myself, find the nearest Men's room and find a stale and scream and let it all out. Then I come back calm and serene and ask the person to speak with me in private and then:
1- State what happened objectively, not who did what
2- State what we expected or needed to happen
3- Make sure the other person understands by asking open ended questions
4- Make sure everyone knows what will happen next and who needs to do what
5- Reach an agreement, "when in doubt- don't act- ASK for help"

Guess I have a different perspective. I've been yelled and screamed at by some of the best leaders I've ever known - US Marines. In a world of "political correctness" and "emotional intelligence", sometimes we censor ourselves when what was really needed - and infinitely more effective - was a genuine, emotional response. As Tincup says, it all depends on the circumstances. To be clear, I'm not a fan of yelling. And like Fred, I believe in "praise in public, punish in private". Business isn't the military, but sometimes the stakes are equally high. This probably won't be a very popular response. Please don't yell at me.

1. Did the manager yell at the employee to keep the employee from getting hurt?
2. Did the manager yell at the employee to get the employee's attention?
3. Did the manager yell at the employee because the manager was frustrated?

If it was item #3, the manager has problem. Let us not be too hard on the yeller even though the yellee seldom deserves the yelling. Employers assign supervisors and managers to their positions for reason other than their ability to effectively supervise direct reports or to control themselves. Goodwill takes time to develop yet can be lost with one or two episodes of unwarranted verbal abuse, real or imagined.

Years ago Sandy, a direct report, came to me because she finished her assignment and needed another one. I said, "Do A then B then C then D then E then F." I gave her six assignments quickly and off the top of my head. Sandy turned and was walking away when she stopped and said, "Mr. Gately, I have a dumb question to ask." I looked at here and said, "Don't you have a masters degree in environmental engineering," and she replied, "you know I do." I followed up with. "Don't you have an undergraduate degree in Mathematics which impresses the heck out of me?" Sandy replied, "Yes." I then said, "Then nothing you could ask me could be a stupid question." Sandy replied, "But I don't know what you want me to do next." I replied, "That is my fault, not yours. Sit down and grab a pencil and a pad of paper and lets make a list."

After Sandy completed the task list I then asked, "Sandy, I have a dumb question, had I said that, 'that was a dumb question,' what would have been your reaction?" Sandy replied, "The first time you did it I would think you were having a bad day. If you did it a second time, it would be your last." Sandy was clear that the goodwill that existed between us could be lost with only two episodes of bad behavior by me.

Too many supervisors and managers either believe or act as if they are the world's best communicators. The responsibility to be understood lies with the speaker and in Sandy's case, it was with me. Some of my clients are at the very upper end of the bell shaped curve of mental abilities. In other words, their minds are like a jet fighter pilot while many of their direct reports are more like an ocean liner captain; they can do their jobs well but not as faster not as error free as the jet fighter pilot. Clients who are in the top 10% are often pleased yet become sad when they realize that their direct reports may be trying to do a good job but they have failed their direct reports by not taking into account their direct reports abilities to remember all of the directions spewed out at them like water from a fire hose.

I always end with, "Never ask a direct report, 'Do you understand what I want or mean?' since what they understand is what they remember so instead ask 'What are you going to do next?' and wait for an answer. If what they are going to do next is what you want them to do next, then ask them "what will you do after you get that done?" It won't take long to learn if they understand what you want them to do.

What is the context of the situation? Is it a one-time outburst or repetitive behavior? Is the intent to frighten or intimidate or is it poor anger management skills? Does the yelling negatively impact the performance of the subordinate or other team members? To my knowledge, there are no laws against bullying although the "The Healthy Workplace Bill" (not enacted in any state) is a possibility but I'm still investigating its value. Yelling happens. Is it appropriate? No. There are always better ways to communicate and provide feedback and organizations are starting to trend to more respectful cultures. Yes the employee can go to HR. Yes HR may ask the employee if he/she talked to the manager or may investigate especially if their is a "no-bullying policy" and the behavior is in direct opposition to organizational core values or performance measures. For your one scenario, if this was a one-time action, it could be just un-professional behavior.

I agree with Lisa. Yelling is never appropriate. We need to be careful with using the word "bully." Similar to harassment, the word bully is getting diluted because it is used often and typically incorrectly. I have spoken on bulling at the SHRM Annual conference and other conferences around the country and want to highlight that bullying is "repeated, health harming" conduct. Does that mean you want to see employees yelled at or demeaned repeatedly before doing something - No. Even the first and only time is inappropriate, but I would watch the labels. Work with the manager and provide directed coaching. I also coach execs who bully and in order to be effective you will want to have specific examples to point out to the manager. Have a workplace bullying policy. If you need one, I am happy to provide the one I give out at conferences and on webinars, just let me know. Bullying or inappropriate conduct such as yelling can have widespread impact on your workforce and should be addressed promptly. Lastly, I recommend to always delve into these situations and to do some type of investigation or inquiry because you never know if there could also be some unlawful conduct going on. Maybe the manager only yells at this particular employee who has some protected characteristic. Or, the manager yells at a particular group. Then, you might be looking at discrimination or harassment. You would have to explore further.

Humans are perfectly imperfect. We are a mix of passion and emotion of thought and insight. I don't think yelling once is bullying. We need to be careful not to sterilize the workplace. That said, it isn't appropriate behaviour and probably needs to be looked at to see why it occurred.

I guess I would like to know more about why and/or what was the context of the events that led up to the yelling. I mean... did the manager just randomly pick this person out of a crowd of employees? I'm looking for justification. Not a popular way to approach this but if the employee just lost a $5M account in a $10M shop... then yelling might be appropriate. If the employee inadvertently threw away a pencil... then yelling isn't appropriate.

Two things to consider... (1) appropriate use and (2) proportionate response.

Btw, I like Fred's five step process a lot.

Yelling is not necessarily bullying. Yelling at a subordinate in public shows a lamentable lack of control and a complete ignorance of proper management techniques.

Yelling also publicly demonstrates extreme displeasure, and is occasionally done deliberately as a lesson to others. Yelling is the traditional test procedure of rites of passage such as initiations and military boot camp and stress excercises, to determine the subject's ability to filter out noise, remain unflappable despite verbal abuse and maintain a disciplined focus; if you can't take harassment from your side, you will be unreliable when provoked by the enemy. But the normal work environment does not require iron nerves and steely resolve during frantic activities in highly stressful situations.

If the employee is placing someone's life at risk, I can see some reason to immediately shout corrective advice rather than take the employee aside for private corrective counseling, but that is about the only proper situation I can think of. Conventional best practice is to make an immediate firm correction and speak privately if more direction is required. As the saying goes, how people behave is a sign of their character, and how you respond is a sign of yours.

Yelling is a typical of a Theory X supervisor. But what happens when the supervisor vents his anger in a public place?

You may easily come across such supervisors in jobs which are target based and involve sales. To put a pressure on the employees, the supervisor resorts to daily/weekly/monthly reviews and yells and publicly humiliates almost everyone in the meting - One by one.

Real apathy arises when you cannot approach the HR as the supervisor is high performer and is liked by his Boss. The HR just timidly counsels the aggrieved employee and promises to 'Look into the matter'.

Needless to say, there are hardly any actions against the performing supervisor.

I hate the over use of the word bullying. Being told off, or even shouted at isn't bullying - try working in a sales environment and see how things really happen!

Bullying is an habitual or systematic attack on someone, either physically or mentally, and not a ticking off. When your wife or husband raises their voice to you - is that bullying or just part of life and relationships? You have a relationship with your work colleagues too, and so sometimes (perhaps) they show their human side!

People need to grow up and take some things on the chin!

Katy,
As others have indicated you don't have to yell at someone to bully them. The questions about context and circumstances are also important.
Unless there is immenent danger involved yelling at someone is inappropriate and unprofessional- whether in private or in public. It can also be a prelude to further inappropriate behavior so I am a believer in nipping it in the bud.
Bullying is one of those terms that we will continue to define. Holding someone accountable is not bullying. Letting them know that their performance is not meeting expectations is not bullying, nor in my opinion is making them aware that behavior such as disrupting a meeting, belaboring a point that has been settled bullying.
I define bully as using the power of your position, strength, intellect, relationships, etc to intindidate or coerce someone as bullying. Not appropriate.