Burlington Northern & Santa Fe Railway Company, Petitioner V. Sheila White
LEGAL ANALYSIS
1. STATEMENT OF FACTS: Sheila White interviewed with Marvin Brown and obtained a job as a “track laborer” with Burlington Northern & Santa Fe Railway Company. Shortly after her hire date, however, she assumed forklift operator duties. This new assignment still fell under the “track laborer” position description, and White occasionally performed those duties although her primary responsibility was operating the forklift. Three months into her new job, White complained to the company that her immediate supervisor was sexually harassing her on the job. He was temporarily suspended and required to attend sexual harassment training. White was then informed that she was being reassigned to track labor duties only. White filed a complaint with the Equal Employment Opportunity Commission (EEOC) claiming that the job reassignment was in retaliation for her sexual harassment complaint.
Two months later after getting into a disagreement with her new supervisor, Brown put White on indefinite suspension without pay for being insubordinate. An internal investigation, however, found that White had not been insubordinate, and after 37 days she was reinstated with back pay. White filed another retaliation complaint with EEOC and, ultimately, took her case to federal court where a jury awarded her $43,500 in compensatory damages. The District Court denied a post-trial motion set by Burlington and eventually the Court of Appeals upheld the District Court’s judgment in favor of White.
2. LEGAL ISSUE STATEMENT: Did Burlington Northern & Santa Fe Railway Company discriminate against employee Sheila White by violating the Anti-retaliation provision of Title VII of Civil Rights Act of 1964 when it 1) assigned her to different job duties after she complained of sexual harassment; and 2) later suspended her without pay?
3. APPLICABLE LEGAL RULES:
a. Under Title VII of the Civil Rights Act of 1964
(Antidiscrimination provision) Sec 703 (a) “It shall be
1. STATEMENT OF FACTS: Sheila White interviewed with Marvin Brown and obtained a job as a “track laborer” with Burlington Northern & Santa Fe Railway Company. Shortly after her hire date, however, she assumed forklift operator duties. This new assignment still fell under the “track laborer” position description, and White occasionally performed those duties although her primary responsibility was operating the forklift. Three months into her new job, White complained to the company that her immediate supervisor was sexually harassing her on the job. He was temporarily suspended and required to attend sexual harassment training. White was then informed that she was being reassigned to track labor duties only. White filed a complaint with the Equal Employment Opportunity Commission (EEOC) claiming that the job reassignment was in retaliation for her sexual harassment complaint.
Two months later after getting into a disagreement with her new supervisor, Brown put White on indefinite suspension without pay for being insubordinate. An internal investigation, however, found that White had not been insubordinate, and after 37 days she was reinstated with back pay. White filed another retaliation complaint with EEOC and, ultimately, took her case to federal court where a jury awarded her $43,500 in compensatory damages. The District Court denied a post-trial motion set by Burlington and eventually the Court of Appeals upheld the District Court’s judgment in favor of White.
2. LEGAL ISSUE STATEMENT: Did Burlington Northern & Santa Fe Railway Company discriminate against employee Sheila White by violating the Anti-retaliation provision of Title VII of Civil Rights Act of 1964 when it 1) assigned her to different job duties after she complained of sexual harassment; and 2) later suspended her without pay?
3. APPLICABLE LEGAL RULES:
a. Under Title VII of the Civil Rights Act of 1964
(Antidiscrimination provision) Sec 703 (a) “It shall be