Law School Case Brief
Landgraf v. usi film prods - 511 U.S. 244, 114 S. Ct. 1483, 128 L. Ed. 2d 229, 1994 U.S. LEXIS 3292
Even absent specific legislative authorization, application of new statutes passed after the events in suit is unquestionably proper in many situations. When the intervening statute authorizes or affects the propriety of prospective relief, application of the new provision is not retroactive.
After Barbara Landgraf (Landgraf) allegedly was sexually harassed by a male employee at the same plant run by Respondent USI Film Products (USI), Landgraf quit her job in 1986 and filed a timely charge with the Equal Employment Opportunity Commission. Subsequently, Landgraf filed a sexual harassment suit against USI in federal district court, alleging sexual harassment creating a hostile work environment in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C.S. § 2000e et seq. During the trial, it was determined that Landgraf was not entitled to a jury trial in a Title VII case. However, the district court also concluded that Landgraf had not been constructively discharged, as the harassment had not been so severe that a reasonable person would have felt compelled to resign, the court dismissed because Landgraf's employment had not been terminated and Title VII did not then authorize any other form of relief. While the worker's appeal was pending, the Civil Rights Act of 1991 (PL 102-166) was enacted, which created a right to recover compensatory and punitive damages for certain violations as well as trial by jury, 42 U.S.C.S. § 1981a. Landgraf petitioned for certiorari review on the question whether to apply the law in effect at the time the discriminatory conduct occurred, or the law that became effective during the appeal.
Does the law, which grants the right to a jury trial in sexual harassment cases under the Civil Rights Act of 1991, have a retroactive application?
The United States Supreme Court affirmed the holding that Landgraf was not entitled to a jury trial in a Title VII sexual harassment case against USI, her former employer, even though USI had committed sexual harassment. The Civil Rights Act of 1991, granting the right to a jury trial to Title IX cases, was not given retrospective operation to a pending appeal.
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