United States First Circuit

In a suit brought by a former TSA employee's alleging claims of sex discrimination and sex harassment in violation of violations of Title VII of the Civil Rights Act of 1964, the District Court's dismissal of plaintiff's supervisor from the suit and subsequent summary judgment in favor of defendant employer is reversed where: 1) the district court erred by requiring her to present direct evidence to establish sex discrimination under the mixed-motives theory; 2) the district court also erred by requiring plaintiff to show that the supervisor's conduct was severe and pervasive to establish sex harassment; and 3) under the correct legal frameworks, there is sufficient circumstantial evidence from which a reasonable jury could find in plaintiff's favor on both claims.

Appellate Information

• Published 2016/07/12

Judges

• LYNCH

Court

• United States First Circuit

Counsel