United States Fourth Circuit

A grant of summary judgment to an employer on Title VII sexual harassment claims is vacated and the case remanded, where: 1) there were genuine issues of fact as to whether the employer took "tangible employment action" against the plaintiff for purposes of the Faragher-Ellerth defense; and 2) there was sufficient uncertainty in the facts about whether there was a nexus between the harassment and plaintiff's alleged termination to find summary judgment inappropriate.

Appellate Information

• Decided 03/12/2012
• Published 03/12/2012

Judges

• Duncan

Court

• United States Fourth Circuit

Counsel

• For Appellant:
  
• Terry Neill Grimes, Lawrence Philip Postol