Policy Guidance on Employer Liability under Title VII = for Sexual Favoritism

From: Subject: Policy Guidance on Employer Liability under Title VII for Sexual Favoritism Date: Thu, 4 Oct 2007 08:39:34 -0400 MIME-Version: 1.0 Content-Type: multipart/related; type="text/html"; boundary="----=_NextPart_000_000E_01C80662.170E3D70" X-MimeOLE: Produced By Microsoft MimeOLE V6.00.2900.3138 This is a multi-part message in MIME format. ------=_NextPart_000_000E_01C80662.170E3D70 Content-Type: text/html; charset="Windows-1252" Content-Transfer-Encoding: quoted-printable Content-Location: http://www.eeoc.gov/policy/docs/sexualfavor.html Policy Guidance on Employer Liability under Title VII = for Sexual Favoritism =0A= The U.S. Equal Employment Opportunity = Commission=20

N-915.048

1/12/90

1. Subject: Policy Guidance on Employer Liability under Title = VII for=20 Sexual Favoritism.

2. Purpose: This policy document is intended to provide = guidance on=20 the extent to which an employer should be held liable for discriminating = against=20 individuals who are qualified for but are denied an employment = opportunity or=20 benefit, where the individual who is granted the opportunity or benefit = received=20 it because that person submitted to sexual advances or requests.

3. Effective Date: On receipt.

4. Expiration Date: As an exception to EEOC Order = 205.001,=20 Appendix B, Attachment 4, =A7 a(5), this Notice will remain in effect = until=20 rescinded or superseded.

5. Originator: Title VII/EPA=20 Division, Office of Legal Counsel.

6. Instructions: File after Section 615 of Volume II of the = Compliance=20 Manual (Harassment).

7. Subject Matter:

Background

The Commission and the courts have declared that sexual harassment = violates=20 Section 703 of Title VII. Meritor Savings Bank v. Vinson, = 477 U.S.=20 57, 64, 40 EPD =B6 31,159 (1986); EEOC's = Guidelines on=20 Discrimination Because of Sex, 29 C.F.R. =A7 1604.11(a). EEOC's = Guidelines=20 define two kinds of sexual harassment: "quid pro quo," in which = "submission to=20 or rejection of [unwelcome sexual] conduct by an individual is used as = the basis=20 for employment decisions affecting such individual," and "hostile = environment,"=20 in which unwelcome sexual conduct "unreasonably interfer[es] with an=20 individual's job performance" or creates an "intimidating, hostile or = offensive=20 working environment." 29 C.F.R. =A7=A7 1604.11(a)(2) and (3).

Subsection (g) of EEOC's = Guidelines=20 provides:

where employment opportunities or benefits are granted because of = an=20 individual's submission to the employer's sexual advances or requests = for=20 sexual favors, the employer may be held liable for unlawful sex = discrimination=20 against other persons who were qualified for but were denied that = employment=20 opportunity or benefit.

As discussed below, sexual favoritism in the workplace which = adversely=20 affects the employment opportunities of third parties may take the form = of=20 implicit "quid pro quo" harassment and/or "hostile work environment"=20 harassment.

Discussion

A. Isolated Instances of Favoritism Towards a "Paramour" Not = Prohibited

Not all types of sexual favoritism violate Title VII.¹=20 It is the Commission's position that Title VII does not prohibit = isolated=20 instances of preferential treatment based upon consensual romantic=20 relationships. An isolated instance of favoritism toward a "paramour" = (or a=20 spouse, or a friend) may be unfair, but it does not discriminate against = women=20 or men in violation of Title VII, since both are disadvantaged for = reasons other=20 than their genders.²=20 A female charging party who is denied an employment benefit because of = such=20 sexual favoritism would not have been treated more favorably had she = been a man=20 nor, conversely, was she treated less favorably because she was a woman. = See Miller v. Aluminum Co. of America, 679 F. Supp. 495, 47 = EPD =B6=20 38,112 (W.D. Pa.), aff'd mem., 856 F.2d 184 = (3d Cir.=20 1988);³=20 DeCintio v. Westchester County Medical Center, 807 F.2d = 304, 42 EPD=20 =B6 36,785 (2d Cir. 1986), cert. denied, 108 S.Ct. 89, 44 = EPD =B6=20 37,425 (1987).⁴=20 But see King. v. Palmer, 778 F.2d 878, 39 = EPD =B6=20 35,808, reh'g denied, 39 EPD =B6 36,036 (D.C. Cir. = 1985).⁵

B. Favoritism Based Upon Coerced Sexual Conduct May Constitute Quid = Pro Quo=20 Harassment

If a female employee⁶=20 is coerced into submitting to unwelcome sexual advances in return for a = job=20 benefit, other female employees who were qualified for but were denied = the=20 benefit may be able to establish that sex was generally made a condition = for=20 receiving the benefit.⁷=20 Thus; in order for a woman to have obtained the job benefit at issue, it = would=20 have been necessary to grant sexual favors, a condition that would not = have been=20 imposed on men. This is substantially the same as a traditional sexual=20 harassment charge alleging that sexual favors were implicitly demanded = as a=20 "quid pro quo" in return for job benefits.⁸=20 For example, in Toscano v. Nimmo, 570 F. Supp. 1197, = 1199-1201, 32=20 EPD =B6 33,848 (D. Del. 1983), the court found a violation of Title VII = based on=20 the fact that the granting of sexual favors was a condition for = promotion.=20 Although the individual who was granted preferential treatment was = engaged in a=20 consensual affair with her supervisor, there was evidence that the = supervisor=20 made telephone calls to proposition several female employees at home, = phoned=20 employees at work to describe his supposed sexual encounters with female = employees under his supervision, and engaged in suggestive behavior at = work.⁹

Many times, a third party female will not be able to establish that = sex was=20 generally made a condition for the benefit in question. For example, a=20 supervisor may have been interested in only one woman and, thus, have = coerced=20 only her. Nevertheless, in such a case, both women and men who were = qualified=20 for but were denied the benefit would have standing to challenge the = favoritism=20 on the basis that they were injured as a result of the discrimination = leveled=20 against the woman who was coerced. See EEOC amicus = brief=20 (filed Sept. 30, 1988) in Clayton v. White Hall School = District,=20 875 F.2d 676, 50 EPD =B6 39,048 (8th Cir. 1989), in which the Commission = argued=20 that a white employee had standing under Title VII to challenge her = employer's=20 decision to deny her an employment benefit pursuant to an employment = policy=20 which it allegedly enforced for the purpose of denying the same benefit = to a=20 black employee; although the plaintiff was not the object of racial=20 discrimination, she was injured as a result of the race discrimination = practiced=20 against the black employee.¹⁰=20 See also DeCintio v. Westchester County Medical=20 Center, 807 F.2d at 307-08 (by implication) (male plaintiffs' = claims of=20 favoritism rejected not because of lack of standing but because the = woman who=20 received the favorable treatment was not coerced into submitting to = sexual=20 advances); EEOC v. = T.I.M.E.-D.C.=20 Freight, Inc., 659 F.2d 690 n.2, 27 EPD =B6 32,202 (5th Cir. = 1981) (white=20 plaintiffs could challenge discrimination against blacks provided that = they=20 could establish a personal injury); Allen v. American Home Foods,=20 Inc., 644 F. Supp. 1553, 42 EPD =B6 36,911 (N.D. Ind. 1986) = (males who lost=20 their jobs due to their employer's discrimination against female = co-workers=20 suffered an injury as a result of the discrimination, and therefore had = standing=20 to sue under Title VII).

C. Widespread Favoritism May Constitute Hostile Environment = Harassment

If favoritism based upon the granting of sexual favors is widespread = in a=20 workplace, both male and female colleagues who do not welcome this = conduct can=20 establish a hostile work environment in violation of Title VII = regardless of=20 whether any objectionable conduct is directed at them and regardless of = whether=20 those who were granted favorable treatment willingly bestowed the sexual = favors.=20 In these circumstances, a message is implicitly conveyed that the = managers view=20 women as "sexual playthings," thereby creating an atmosphere that is = demeaning=20 to women. Both men and women who find this offensive can establish a = violation=20 if the conduct is "sufficiently severe or pervasive 'to alter the = conditions of=20 [their] employment and create an abusive working environment.'"=20 Vinson, 477 U.S. at 67 [quoting Henson v. City of=20 Dundee, 682 F.2d 897, 904, 29 EPD =B6 32,993 (11th Cir. 1982)].¹¹=20 An analogy can be made to a situation in which supervisors in an office=20 regularly make racial, ethnic or sexual jokes. Even if the targets of = the humor=20 "play along" and in no way display that they object, co-workers of any = race,=20 national origin or sex can claim that this conduct, which communicates a = bias=20 against protected class members, creates a hostile work environment for = them.=20 See Rogers v. EEOC, = 454 F.2d=20 234, 4 EPD =B6 7597 (5th Cir. 1971), cert. denied, 406 U.S. 957, = 4 EPD =B6=20 7838 (1972) (discriminatory treatment of medical patients created = hostile work=20 environment for plaintiff employee); Commission Decision No. 71-969, CCH = EEOC=20 Decisions (1973) =B6 6193 (supervisor's habitual use of racial epithet = in=20 referring to Black employees created discriminatory work environment for = White=20 Charging Party); Compliance Manual Volume II, Section 615.3(a)(3) = Examples (1)=20 and (2) (sexual harassment of females may create hostile work = environment for=20 other male and female employees).

Managers who engage in widespread sexual favoritism may also = communicate a=20 message that the way for women to get ahead in the workplace is by = engaging in=20 sexual conduct or that sexual solicitations are a prerequisite to their = fair=20 treatment.¹²=20 This can form the basis of an implicit "quid pro quo" harassment claim = for=20 female employees, as well as a hostile environment claim for both women = and men=20 who find this offensive.¹³

The case of Broderick v. Ruder, 685 F. Supp. 1269, 46 = EPD =B6=20 37,963 (D.D.C. 1988) illustrates how widespread sexual favoritism can be = found=20 to violate Title VII. In Broderick a staff attorney at the=20 Securities and Exchange Commission alleged that two of her supervisors = had=20 engaged in sexual relationships with two secretaries who received = promotions,=20 cash awards, and other job benefits. Another of her supervisors = allegedly=20 promoted the career of a staff attorney with whom he socialized = extensively and=20 to whom he was noticeably attracted. In addition, there were isolated = instances=20 of sexual harassment directed at the plaintiff herself, including an = incident in=20 which her supervisor became drunk at an office party, untied the = plaintiff's=20 sweater, and kissed her. The court found that the conduct of these = supervisors=20 "created an atmosphere of hostile work environment" offensive to the = plaintiff=20 and several other witnesses. It further stated that the supervisors' = conduct in=20 bestowing preferential treatment upon those who submitted to their = sexual=20 advances undermined the plaintiff's motivation and work performance and = deprived=20 her and other female employees of promotions and job opportunities.=20 Broderick, 685 F. Supp. at 1278. While the court in=20 Broderick grounded its ruling on the hostile environment = theory, it=20 is the Commission's position that these facts could also support an = implicit=20 "quid pro quo" harassment claim since the managers, by their conduct,=20 communicated a message to all female employees in the office that job = benefits=20 would be awarded to those who participated in sexual conduct. See = also Spencer v. General Electric, 697 F. Supp. 204 = (E.D. Va.=20 1988).¹⁴

Example 1 - Charging Party (CP) alleges that she lost a = promotion for=20 which she was qualified because the co-worker who obtained the = promotion was=20 engaged in a sexual relationship with their supervisor. EEOC's = investigation=20 discloses that the relationship at issue was consensual and that the=20 supervisor had never subjected CP's=20 co-worker or any other employees to unwelcome sexual advances. The = Commission=20 would find no violation of Title VII in these circumstances, because = men and=20 women were equally disadvantaged by the supervisor's conduct for = reasons other=20 than their genders.

Even if CP is genuinely = offended=20 by the supervisor's conduct, she has no Title VII = claim.

Example 2 - Same as above, except the relationship at = issue=20 was not consensual. Instead, CP's supervisor regularly harassed = the=20 co-worker in front of other employees, demanded sexual favors as a = condition=20 for her promotion, and then audibly boasted about his "conquest." In = these=20 circumstances, CP may be = able to=20 establish a violation of Title VII by showing that in order to have = obtained=20 the promotion, it would have been necessary to grant sexual favors. In = addition, she and other qualified men and women who were denied the = promotion=20 would have standing to challenge the favoritism on the basis that they = were=20 injured as a result of the discrimination levelled against their=20 co-worker.

Example 3 - Same as Example 1, except CP's supervisor and other = management=20 personnel regularly solicited sexual favors from subordinate employees = and=20 offered job opportunities to those who complied. Some of those = employees=20 willingly consented to the sexual requests and in turn received = promotions and=20 awards. Others consented because they recognized that their = opportunities for=20 advancement would otherwise be limited. CP, who did not welcome this = conduct, was not=20 approached for sexual favors. However, she and other female and male = coworkers=20 may be able to establish that the conduct created a hostile work = environment.=20 She can also claim that by their conduct, the managers communicated to = all=20 female employees that they can obtain job benefits only by acquiescing = in=20 sexual conduct.

1/12/90                      =
Approved:     /s/
Date                                   Clarence Thomas
                                       Chairman

¹ The material in =A7 615 of the = Compliance=20 Manual on subsection (g) of the Guidelines (at pp. 615-10 and 11) is = superseded=20 by this Policy Guidance.=20

² See Benzies v. = Illinois=20 Dept. of Mental Health, 810 F.2d 146, 148, 39 EPD =B6 35,870 (7th = Cir.),=20 cert. denied, 107 S.Ct. 3231 (1987) (denial of promotion to = woman=20 is not violation if motivated by personal or political favoritism or a = grudge);=20 Bellissimo v. Westinghouse Electric Corp., 764 F.2d 175, = 180, 37=20 EPD =B6 35,315 (3d Cir. 1985), cert. denied, 475 U.S. 1035, = 39 EPD =B6=20 35,875 (1986) (discharge of female employee violates Title VII only if = it is=20 done on a basis that would not result in the discharge of a male = employee)

³ The plaintiff in = Miller=20 alleged that her supervisor treated her less favorably than her = co-worker=20 because the supervisor knew that the co-worker was engaged in a romantic = relationship with the plant manager. Miller, 679 F. Supp. = at=20 500-01. The lower court held that in order to establish a Title VII = claim, the=20 plaintiff would have to show that her employer would have or did treat = males=20 differently. Id. at 501. Since the plaintiff's male = co-workers=20 shared with her the same disadvantage relative to the co-worker who was = engaged=20 in the affair with the manager, the plaintiff could not show that she = was=20 treated differently than males. Id. On appeal to the Third = Circuit,=20 the Commission filed an amicus brief supporting the ruling of the = district court=20 on the basis that favoritism toward a female employee because of a = consensual=20 romantic relationship with a male supervisor is not sex discrimination = against=20 other female employees within the meaning of Title VII. The Court of = Appeals=20 summarily affirmed.

⁴ In DeCintio, = seven male=20 respiratory therapists claimed that they were unlawfully disqualified = for a=20 promotion that went to a woman who was engaged in a romantic = relationship with=20 the department administrator. The court held that the department = administrator's=20 conduct, though unfair, did not violate Title VII. = DeCintio, 807=20 F.2d at 308. The court reasoned that the prohibition of sex = discrimination in=20 Title VII refers to discrimination on the basis of one's sex, not on the = basis=20 of one's sexual affiliations; the therapists' claims were not cognizable = under=20 the Act since they were denied promotion because the administrator = preferred his=20 "paramour," rather than because of their status as males. = Id. The=20 court distinguished EEOC's = Guidelines by=20 stating that they address the granting of employment benefits because of = an=20 individual's "submission" to sexual advances or requests, and the word=20 "submission" connotes a lack of consent. Since the department = administrator did=20 not force anyone to submit to sexual advances in order to win promotion, = his=20 conduct was not within the purview of the Guidelines. Id. = at=20 307-08. Accord, Handley v. Phillips, 715 F. = Supp. 657,=20 675 (M.D. Pa. 1989).

⁵ In King, the = plaintiff=20 claimed she had been denied a promotion that went to a less qualified = co-worker=20 who was engaged in an intimate relationship with the selecting official. = Although the issue of whether Title VII applied to preferential = treatment was=20 not raised on appeal, the court stated that it agreed with the lower = court's=20 conclusion that the case was within the purview of Title VII. = King,=20 778 F.2d at 880. The court ruled in favor of the plaintiff on the basis = of its=20 finding that her co-worker was promoted because of the sexual = relationship.=20 Id. at 882. In a concurring opinion to the decision denying = a=20 suggestion for rehearing en banc, it was = emphasized=20 that the issue of whether Title VII applied to the facts of the case was = not=20 raised on appeal or in the petition for rehearing. 39 EPD =B6 = 36,036.

⁶ Although this Policy Guidance = uses=20 female pronouns to refer to individuals who are treated favorably = because they=20 engage in sexual conduct, it also covers situations in which men are = granted=20 favorable treatment based on sexual conduct.

⁷ The employer would also be = liable for=20 "quid pro quo" harassment with regard to the individual who was coerced = into=20 submitting to the advances.

⁸ See Section 1604.11(l) = of=20 EEOC's=20 Guidelines on Sexual Harassment, which states that a violation will be = found=20 when submission to unwelcome sexual conduct is made "either explicitly = or=20 implicitly" a term or condition of an individual's employment.

⁹ See also=20 DeCintio v. Westchester County Medical Center, 807 F.2d at = 307, in=20 which the court stated that the claim in Toscano was = premised on=20 the coercive nature of the employer's acts, and therefore that the case = lent no=20 support to the contention that a voluntary amorous involvement may form = the=20 basis of a Title VII claim.

¹⁰ In Clayton, = the court=20 ruled that the plaintiff did have standing, but it based that standing = on her=20 allegation of a hostile work environment. 875 F.2d at 679.

¹¹ See EEOC's = Policy Guidance=20 on Current Issues of Sexual Harassment (10/25/88) at 13-18 for standards = governing the determination of whether a work environment is "hostile". = That=20 Policy Guidance makes clear that the Commission will evaluate the = totality of=20 circumstances on a case-by-case basis, employing the objective = perspective of a=20 "reasonable person" in the context in which the challenged conduct took = place.=20 Some factors that could be considered in determining whether a hostile=20 environment is established are the number of incidents of favoritism, = the=20 egregiousness of the incidents, and whether or not other employees in = the office=20 were made aware of the conduct.

¹² See, e.g., = Priest=20 v. Rotary, 634 F. Supp. 571, 39 EPD =B6 35,897 (N.D. Cal. = 1986), in=20 which the defendant gave preferential treatment to his consensual sexual = partner=20 and to those female employees who reacted favorably to his sexual = advances and=20 other conduct of a sexual nature, and he disadvantaged those employees,=20 including the plaintiff, who reacted unfavorably to his conduct. The = court found=20 a violation of Title VII in part because the defendant's conduct implied = that=20 job benefits would be conditioned on an employee's good-natured = endurance of his=20 sexually-charged conduct or sexual advances. Id. at = 581.

¹³ In Miller v. Aluminum = Co. of=20 America, 679 F. Supp. at 501- 502, the court rejected a claim = that sexual=20 favoritism based on a consensual relationship can create a hostile = environment=20 for others in the workplace. The court found that the favoritism itself = did not=20 violate Title VII since it was voluntary, and that "[h]ostile behavior = that does=20 not bespeak an unlawful motive cannot support a hostile work environment = claim."=20 Id. at 502. However, it is the Commission's position that = had the=20 sexual favoritism been widespread, the fact that it was exclusively = voluntary=20 and consensual would not have defeated a claim that it created a hostile = work=20 environment for other people in the workplace. As indicated above at = n.11, the=20 question of whether actions complained of are sufficiently widespread or = egregious to constitute a hostile environment must be decided = case-by-case.

¹⁴ In Spencer, = the=20 supervisor of an office engaged in virtually daily horseplay of a sexual = nature=20 with female subordinates. This behavior included sitting on their laps, = touching=20 them in an intimate manner, and making lewd comments. The subordinates = joined in=20 and generally found the horseplay funny and inoffensive. With the = exception of=20 one incident (which may have been time-barred and was not critical to = the=20 court's decision), none of the horseplay was directed at the plaintiff. = The=20 supervisor additionally engaged in consensual relations with at least = two of his=20 subordinates. The court found that the supervisor's conduct would have=20 interfered with the work performance and would have seriously affected = the=20 psychological well-being of a reasonable employee, and on that basis it = found a=20 violation of Title VII. 697 F. Supp. at 218. Although = Spencer did=20 not involve sexual favoritism, the case supports the proposition that = pervasive=20 sexual conduct can create a hostile work environment for those who find = it=20 offensive even if he targets of the conduct welcome it and even if no = sexual=20 conduct is directed at the persons bringing the claim.

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