McMiller v. Metro, No. 12-3536 (8th Cir. 2013)
Annotate this CasePlaintiff filed suit against her former employer, Metro, alleging that her supervisor had sexually harassed her in violation of Title VII, 42 U.S.C. 2000e et seq. On appeal, plaintiff challenged the district court's grant of summary judgment in favor of Metro. The court concluded that the supervisor's alleged conduct was not so severe or pervasive as to alter the terms and conditions of plaintiff's employment and, therefore, affirmed the district court's grant of summary judgment on plaintiff's hostile work environment claim. The court concluded, however, that plaintiff presented genuine issues of fact as to whether the supervisor was motivated by sex and whether he intentionally and proximately caused her termination. Accordingly, the court reversed the district court's grant of summary judgment on this quid pro quo harassment claim.
Court Description: Civil case - Civil rights. Under circuit precedents, plaintiff's supervisor's conduct was not so severe or pervasive as to alter the terms and conditions of her employment, and the district court did not err in granting defendant's motion for summary judgment on plaintiff's hostile work environment claim; plaintiff's evidence that her supervisor demanded sexual favors in exchange for influencing the employer's decision to continue plaintiff's employment and that she was terminated for failing to cooperate with the supervisor's attempts to engage her sexually was sufficient to state a quid pro quo harassment claim, and the district court erred in granting defendant's motion for summary judgment on the claim. Judge Murphy, concurring in part and dissenting in part.
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