Questions and Answers
What is the Court of Appeals?
The district court entered judgment for Faragher on her Title VII claim against the City, awarding her $1 in nominal damages.
What standard does the Court of Appeals use for reviewing a district court's finding of fact?
What argument does Faragher make regarding the City's liability?
Faragher argues that the status of the supervisors combined with their conduct makes the City liable for hostile environment sexual harassment.
In a pure hostile environment case, a supervisor's harassing conduct is typically within the scope of his employment.
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Strict liability is logical in a pure hostile environment setting.
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What did the district court find regarding supervisors' conduct?
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What did the U.S. Supreme Court address in this case?
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The affirmative defense requires a showing that the employer exercised reasonable care to avoid ______.
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The affirmative defense requires that the complaining employee failed to act with '______' to take advantage of the employer's safeguards.
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The claim categorized as a hostile work environment only required a showing of isolated incidents.
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What does the Court state regarding an employer's obligation?
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What principle does the Court state about victims recovering damages?
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How long did the harassment alleged in this case occur?
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What did the City's Employment Handbook state regarding complaints?
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An employer can be held vicariously liable if a supervisor creates a hostile work environment, even without adverse employment consequences.
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What significant action did the Equal Employment Opportunity Commission (EEOC) take in March 1990?
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Who authored the opinion for the U.S. Supreme Court in the case argued on March 25, 1998?
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Boca Raton had a sexual harassment policy that was distributed to lifeguards.
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Study Notes
Court of Appeals
- The district court awarded Faragher $1 in nominal damages after ruling in her favor on her Title VII claim against the City.
- Findings of fact by the district court are reviewed under the "clearly erroneous" standard.
- Faragher contended that the conduct of supervisors Terry and Silverman rendered the City liable for hostile environment sexual harassment.
- In pure hostile environment cases, a supervisor's harassing conduct is generally considered outside the scope of employment.
- Strict liability principles do not apply in a pure hostile environment scenario.
- Harassment perpetrated by a supervisor may fall within the scope of their employment, as highlighted in a prior case.
Federal Highlights
- The district court determined that supervisors’ actions created an abusive working environment, resulting in the City being held responsible.
- The Supreme Court granted certiorari to address differing standards on employer liability among various Courts of Appeals regarding supervisory harassment.
- Employers can raise an affirmative defense by demonstrating they exercised reasonable care to prevent and address harassment.
- Complainants must show that they acted with "reasonable care" to utilize the employer’s safeguards and prevent avoidable harm.
UCSC (U.S. Court System Commentary)
- The Court's opinion elaborated on different bases for imposing employer liability due to supervisor actions.
- Employees subjected to harassment may hesitate to report due to fear of repercussions from their supervisor.
- The Court aims to establish a clear statutory policy to aid Title VII enforcement, recognizing employer obligations to prevent harassment.
- Victims cannot recover damages if they failed to take reasonable steps to utilize their employer's preventive measures.
Legal Info Institute
- The harassment in this case occurred intermittently over a five-year period, from 1985 to 1990.
- The City's Employment Handbook allowed employees to discuss complaints with the Personnel and Labor Relations Director.
- Without adverse employment consequences, an employer cannot be held vicariously liable if a supervisor creates a hostile work environment, as stated in a dissenting opinion regarding another case.
- In March 1990, the EEOC issued guidelines encouraging employers to create complaint procedures for sexual harassment.
Encyclopedia
- The case was argued before the Supreme Court on March 25, 1998, with Justice David Souter authoring the opinion.
- Boca Raton had a sexual harassment policy, but it was not distributed to lifeguards, potentially creating an awareness gap.
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Description
Test your knowledge of the landmark case Faragher v. City of Boca Raton with these flashcards. The quiz focuses on legal terminology and significant court rulings related to Title VII claims. Perfect for law students and those interested in civil rights law.