Law School Case Brief
Sutton v. Temple Univ. - CIVIL ACTION NO. 92-0799, 1993 U.S. Dist. LEXIS 11438 (E.D. Pa. Aug. 13, 1993)
A plaintiff who claims that she is sexually harassed has a cause of action under Section 703 of Title VII of the Civil Rights Act of 1964, 42 U.S.C.S. §§ 2000e - 2000e-17, if the sexual harassment is either a quid pro quo arrangement, i.e., harassment that involves the conditioning of employment benefits on sexual favors; or if the harassment is so pervasive that it has the effect of creating an intimidating, hostile or offensive work environment.
The plaintiff, Marsheila Sutton is an employee at Temple University's Center for Research in Human Development and Education (CRHDE). Sutton brought an action against the state university after she was terminated, claiming that the university violated her rights under Title VII of the Civil Rights Act of 1964. Sutton alleged that her termination was in retaliation for filing a sexual harassment claim and that she was subjected to quid pro quo harassment and a sexually hostile work environment.
Did Temple University violate Sutton’s rights under Title VII of the Civil Rights Act of 1964?
The district court found that Sutton failed to prove a prima facie case of retaliation. Although Sutton engaged in protected activity, she had not demonstrated that any adverse employment action was taken against her in retaliation for the filing of a sexual discrimination claim. Sutton’s position terminated as a matter of course when the grant funds for the position were expended. Sutton also failed to demonstrate a Title VII claim based on quid pro quo harassment or hostile environment. With respect to the claim for quid pro quo harassment, Sutton had not credibly demonstrated that she was subjected to unwelcome sexual harassment in the form of sexual advances or requests for sexual favors by her supervisor. Finally, Sutton had not demonstrated a prima facie case of retaliation because she failed to prove that adverse action was taken against her. Judgment was entered for the employer, Temple University.
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