Faragher v. City of Boca Raton facts for kids
Quick facts for kids Faragher v. City of Boca Raton |
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| Argued March 25, 1998 Decided June 26, 1998 |
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| Full case name | Beth Ann Faragher, Petitioner v. City of Boca Raton |
| Citations | 524 U.S. 775 (more)
118 S. Ct. 2275; 141 L. Ed. 2d 662; 1998 U.S. LEXIS 4216; 66 U.S.L.W. 4643; 77 Fair Empl. Prac. Cas. (BNA) 14; 73 Empl. Prac. Dec. (CCH) ¶ 45,341; 157 A.L.R. Fed. 663; 98 Cal. Daily Op. Service 5048; 98 Daily Journal DAR 7000; 1998 Colo. J. C.A.R. 3375; 11 Fla. L. Weekly Fed. S 699
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| Prior history | Ruling in favor of plaintiff, 864 F. Supp. 1552 (S.D. Fla. 1994); reversed, 76 F.3d 1155 (11th Cir. 1996); vacated, 83 F.3d 1346 (11th Cir. 1996); on rehearing en banc, 111 F.3d 1530 (11th Cir. 1997); cert. granted, 522 U.S. 978 (1997). |
| Subsequent history | On remand, 166 F.3d 1152 (11th Cir. 1999). |
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| An employer is vicariously liable for actionable discrimination caused by a supervisor, but subject to an affirmative defense looking to the reasonableness of the employer's conduct as well as that of the plaintiff. | |
| Court membership | |
| Case opinions | |
| Majority | Souter, joined by Rehnquist, Stevens, O'Connor, Kennedy, Ginsburg, Breyer |
| Dissent | Thomas, joined by Scalia |
Faragher v. City of Boca Raton, 524 U.S. 775 (1998), was an important US labor law case decided by the Supreme Court of the United States. This case helped clarify when an employer can be held responsible for the actions of their supervisors. Specifically, it looked at situations where supervisors might create a difficult work environment.
The Court decided that an employer is generally responsible for harmful actions by a supervisor. However, there's also a special defense. This defense considers how reasonably the employer acted and how reasonably the person who was harmed acted.
Contents
What Happened in the Case?
Lifeguard's Complaint Against Supervisors
The case started when Beth Ann Faragher, a lifeguard for the City of Boca Raton, resigned from her job. In 1992, she told the city that her supervisors, Bill Terry and David Silverman, were creating a "hostile atmosphere" at work.
She reported that there was constant unwanted touching and that the supervisors often spoke about women in disrespectful ways. Faragher said these actions made her feel very uncomfortable.
Specific Examples of Harassment
Faragher shared specific examples of what the supervisors did. She claimed that Bill Terry once said he would never promote a woman to a higher rank. David Silverman allegedly told her, "Date me or clean the toilets for a year."
Faragher stated that these supervisors often made similar comments to her and other female lifeguards. Other lifeguards confirmed that these things happened.
City's Response and Other Complaints
Faragher was not the only one who experienced this behavior. Another lifeguard, Nancy Ewanchew, also complained to the City's Personnel Director. She hoped to stop the disrespectful comments, but the behavior continued.
A key point raised against Faragher was that if the problem had been going on for a while, she should have reported it to the City sooner.
The Court's Decision
Lower Court's View on Supervisor Actions
The lower court, the Eleventh Circuit, first looked at the case. It noted that supervisors Terry and Silverman were acting on their own, not as part of their official job duties. The court felt that their relationship with the City did not explain why they treated their co-workers poorly.
The court also pointed out that neither supervisor threatened to fire Faragher or demote her. Because of this, the lower court believed their position as supervisors did not "help" them in their actions.
Why the City Was Not Held Responsible (Initially)
The lower court reviewed the evidence and found no strong reason to believe the City should have known about the problems. It noted that the unwanted actions happened sometimes, over a long time, and at a distant location.
The court thought that if this was such a serious issue, the lifeguards, including Faragher, should have told the City earlier. The Court of Appeals decided the City was not responsible for what its employees did.
Supreme Court's Ruling on Employer Responsibility
Faragher argued that the supervisors' authority actually helped them carry out their actions. She believed they used their power to control workers while making disrespectful comments.
The Supreme Court, led by Justice David H. Souter, looked at the case again. The Court decided that the City was responsible for the supervisors' actions under a law called Title VII of the Civil Rights Act of 1964.
However, the Court also said that employers can use a special defense. This defense allows an employer to avoid responsibility if they can show they took reasonable steps to prevent and correct such behavior, and if the employee unreasonably failed to use those steps.
