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JLA 240 Case Brief: Company V. 548 US

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Eamon Proudfoot
JLA 240 Case Brief Three

BURLINGTON NORTHERN AND SANTA FE RAILWAY
COMPANY v. White
548 U. S. 53 (2006)

Facts: In June 1997, the defendant was the only female worker employed by the plaintiff, a railroad company. Her duties as a track laborer included operating a forklift. She filed a complaint against her supervisor for inappropriate remarks and comments relating to gender in the workplace; she was informed the supervisor was reprimanded. The defendant was then informed by her interviewer that her duties had been changed to track laborer alone with no forklift operation. This was done in response to coworker complaints, which still constituted gender biased speech. The defendant filed two formal complaints with EEOC, one in October for retaliation of the informal complaint and a second in December for the interviewer monitoring her activities. A third complaint was filed shortly after as a result of a 37-day suspension which arose after a disagreement over transportation. The plaintiff gave the …show more content…
The jury awarded her damages based on retaliation but rejected part of her gender discrimination claim. During appeal, the sixth circuit court initially agreed with the company, but was reheard with a decision for the defendant. The supreme court reviewed and affirmed the circuit court’s decision and ruled in favor of the defendant. Issue: Does title VII anti-retaliation provision of the Civil Rights Act of 1964 prohibit employer actions which cause harm to employee only in relation to the employment and the workplace? What severity of retaliatory discrimination constitutes a violation of the provision?

Holding: No, prohibited actions and harmful effects under the provision are not confined to just those that occur at the workplace or are solely related to

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