Williams v. Herron, No. 11-2894 (8th Cir. 2012)
Annotate this CasePlaintiff brought suit under 42 U.S.C. 1983 against the County of Dakota, Nebraska, and former county official Rodney Herron. Plaintiff alleged defendants committed gender discrimination in violation of her Fourteenth Amendment rights. Herron appealed the district court's denial of summary judgment, asserting that he was entitled to qualified immunity. The Eighth Circuit Court of Appeals affirmed, holding (1) Plaintiff met her burden to show that Herron violated her Fourteenth Amendment right to be free from gender discrimination; (2) the right Herron violated was clearly established; and (3) because Plaintiff satisfied both prongs of the qualified-immunity analysis, the district court correctly found that Herron was not entitled to qualified immunity.
Court Description: Civil case - Employment Discrimination. In action alleging defendant sexually harassed plaintiff by creating and fostering a hostile work environment in violation of plaintiff's Fourteenth Amendment rights, the district court did not err in denying defendant's motion for summary judgment based on qualified immunity as plaintiff sufficiently showed defendant's conduct toward her was unwelcome harassment, that it was serious enough to alter a term or condition of her employment and that it violated a clearly established right.
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