Defendants Denied Summary Judgment On Female Correction Officer's Claim Of Sexually Hostile Work Environment
In
this case, the United States District Court held that a
New York county sheriff's department was not entitled to summary judgment on a
female correction officer's claims of a sexually hostile work environment. A
genuine issue of material fact existed as to whether her treatment was severe
and pervasive. Although sexually-tinged remarks directed at her, standing alone,
would likely not withstand the motion for summary judgment, they did when
combined with her account of disparate treatment, failure to promote, and
inappropriate discipline. That her claims raised a triable issue for a jury was
further bolstered by the fact both the alleged harassment and discrimination
occurred at the hands of her superiors. Further, the fact she complained about
her treatment to the unit supervisor and sheriff and posted an article regarding
harassment on the unit's message board was sufficient to raise an inference that
she subjectively believed her environment to be hostile.
Anderson v. Nassau
County Dept. of Corrections