EEOC v. CRST Van Expedited, Inc., No. 09-3764 (8th Cir. 2012)
Annotate this CaseThe EEOC filed suit against CRST, one of the country's largest interstate trucking companies, alleging that CRST subjected Monika Starke "and approximately 270 similarly situated female employees" to a hostile work environment, in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq. The EEOC alleged that CRST was responsible for severe and pervasive sexual harassment in its New-Driver Training program. The court reversed the district court's grant of summary judgment on the EEOC's claims as to Starke because the EEOC, suing as plaintiff in its own name under section 706 of Title VII, could not be judicially estopped because of Starke's independent conduct; reversed the district court's grant of summary judgment on the EEOC's claims on behalf of Tillie Jones because the EEOC had produced sufficient evidence to create a genuine fact issue as to the severity or pervasiveness of harassment that she allegedly suffered; vacated, without prejudice, the district court's award of attorneys' fees to CRST because CRST was no longer a "prevailing" defendant under 42 U.S.C. 2000e-5(k); and affirmed the remainder of the district court's orders and remanded for further proceedings.
Court Description: Civil case - Employment Discrimination. In an action by the EEOC alleging CRST subjected approximately 270 female employees to a hostile work environment in violation of Title VII, the district court erred in granting summary judgment against the EEOC on its claims involving three of the plaintiffs because the EEOC, suing as a plaintiff in its own name under Section 706 of Title VII, may not be judicially estopped because of the employees' independent conduct; however, the court did not err in granting CRST summary judgment on two of the employees because the harassment was not severe or pervasive or because CRST promptly remedied the situation; EEOC wholly failed to satisfy its statutory pre-suit obligations as to 67 women, and the district court did not err in barring the EEOC from pursuing claims as to these women; CRST Lead Drivers were merely the women trainees' coworkers and not their supervisors, and CRST could not be vicariously liable for sexual harassment perpetrated by the Lead Drivers; district court did not err in granting summary judgment for CRST on the EEOC's hostile work- environment claims on behalf of 12 women as the alleged harassment was not sufficiently severe or pervasive; the district court erred in granting summary judgment against the EEOC on its claims on behalf of Tillie Jones because the EEOC produced sufficient evidence to create a genuine fact issue as to the severity or pervasiveness of harassment suffered by Jones; as to 25 women, the EEOC failed to investigate or conciliate its claims on behalf of four of them and the district court's summary judgment is affirmed on the ground that the EEOC failed to discharge its pre-suit duties under Title VII; the district court did not err in granting CRST summary judgment with respect to the claims for the other 21 women because the EEOC failed to create a genuine issue of material fact as to whether CRST knew or should have known of the harassment and failed to take prompt and remedial action; award of attorneys' fees to CRST vacated and remanded. Judge Murphy, concurring in part and dissenting in part.
The court issued a subsequent related opinion or order on May 8, 2012.
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