United States Fourth Circuit
Howard v. Winter, 05-1258
In case alleging hostile work environment under Title VII, summary judgment for defendant in his personal capacity as Secretary of the Navy is vacated where: 1) there is a question of fact whether plaintiff is alleging harassment based on her sex; 2) a reasonable juror could find that plaintiff's comments to a Navy human resources specialist were sufficient to put the Navy on notice of a potential hostile work environment; and 3) the Navy's response to that notice was negligent.
Appellate Information
- Decided 05/04/2006
- Published 05/04/2006
Judges
Court
- United States Fourth Circuit