Crutcher-Sanchez v. Wagner, No. 11-2896 (8th Cir. 2012)
Annotate this CasePlaintiff sued her former employer, Dakota County, Nebraska under 42 U.S.C. 1983 and 1985. She also sued a sheriff, chief deputy, and sergeant, claiming the chief deputy and sheriff created or fostered a sexually hostile work environment, and the chief deputy and sergeant conspired to deprive her of her civil rights. The defendants moved for summary judgment based on qualified immunity, which the district court denied. The Eighth Circuit Court of Appeals (1) affirmed the denial of summary judgment to the chief deputy, holding that Plaintiff sufficiently showed the five elements of a hostile-work-environment sexual harassment claim and that the right the chief deputy violated was clearly established; (2) reversed the denial of summary judgment as to the sheriff and sergeant on Plaintiff's claim that they conspired to violate her constitutional rights, as Plaintiff failed to demonstrate the existence of a conspiracy; and (3) reversed the denial of summary judgment as to the sheriff on Plaintiff's sexually hostile work environment claim, as the sheriff's conduct was not sufficiently severe to create a sexually hostile work environment.
Court Description: Civil case - Employment Discrimination. District court did not err in denying defendant Herron's motion for summary judgment based on qualified immunity as Herron's acts subjected plaintiff to unwelcome harassment that was severe and pervasive enough to alter the terms and conditions of plaintiff's employment, and plaintiff had a clearly- established right to be free of such harassment; district court erred in denying defendants Herron and Ramirez summary judgment on plaintiff's conspiracy claim as she failed to demonstrate the existence of a conspiracy to violate her rights; defendant Wagner was entitled to summary judgment as his conduct was not sufficiently severe or pervasive to create a sexually hostile work environment.
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