Catherine Kim v. Coach, Inc., 692 F. App'x 478

Kim appeals judgment for Coach on Title VII and Hawaii harassment claims.
District court granted summary judgment for Coach on Title VII claim.
Court applied Vance to determine supervisor status of Dungca and Kudo.
Only Makiya, Ala Moana Store general manager, had authority to take tangible employment actions.
Evidence shows Dungca and Kudo directed tasks but lacked power to cause tangible employment actions.
Court affirmed summary judgment and did not reach merits of retaliation claim beyond harmless error analysis.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Dungca and Kudo are supervisors under Vance.	Kim argues they directed her and discussed policies.	Coach contends only Makiya had authority to take tangible actions.	Not supervisors; only Makiya had such authority.
Whether Hawaii law follows Vance on supervisor/harassment standard.	Kim argues Hawaii should apply a broader standard.	Coach defends applying Vance as persuasive; Hawaii would follow Title VII guidance.	Summary judgment sustained; Vance applicable under Hawaii law.
Whether dismissal of retaliation claim with prejudice was proper.	Kim contends prejudice dismissal affected merits.	Not addressed on merits; district record incomplete.	No reversible error; any error harmless.

Vance v. Ball State Univ., 133 S. Ct. 2434 (U.S. 2013) (supervisor doctrine clarification for Title VII harassment)
Burlington Indus., Inc. v. Ellerth, 524 U.S. 742 (U.S. 1998) (authority to take tangible employment actions defines supervisor status)
Feldman v. Allstate Ins. Co., 322 F.3d 660 (9th Cir. 2003) (de novo review standard on Title VII/summary judgment)
Lales v. Wholesale Motors Co., 328 P.3d 341 (Haw. 2014) (Hawaii follows Title VII guidance unless statutory difference)
Bolker v. Comm’r, 760 F.2d 1039 (9th Cir. 1985) (preserves arguments raised on appeal; harmless error doctrine)
Furukawa v. Honolulu Zoological Soc., 936 P.2d 643 (Haw. 1997) (Hawaii Supreme Court on statutory guidance)