Charvette Williams v. Rodney Herron
687 F.3d 971
8th Cir.2012Background
- Williams sued the County of Dakota and former jail administrator Herron under 42 U.S.C. § 1983 for gender discrimination/hostile work environment; district court denied summary judgment on qualified immunity grounds.
- Herron had direct authority over DCJ until Jan 2008 and remained in supervisory role thereafter; Williams could not disregard his orders.
- Beginning Apr/May 2008, Williams and Herron engaged in a sexual relationship that continued until Aug 2008; Williams expressed desire to end it in June/July 2008.
- In July 2008, Herron purportedly harassed Williams at work—grabbing, hugging, unwanted attention, and a sexual encounter initiated by him.
- Williams became pregnant by Herron; she miscarried after a suicide attempt; she avoided him and transferred to the night shift to reduce contact.
- On appeal, Herron challenges the denial of summary judgment, asserting qualified immunity; the court addresses whether a hostile-work-environment claim was violated and whether the right was clearly established.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Herron violated Williams’s Fourteenth Amendment right. | Williams showed unwelcome sexual harassment based on sex that affected employment. | Herron contends there was no actionable harassment or causal link to employment conditions. | Yes, Williams showed actionable hostile-work-environment claim. |
| Whether the violated right was clearly established at the time. | The conduct violated clearly established hostile-work-environment doctrine. | Anderson-like limitations argued; right not clearly established for this case. | Yes, the right was clearly established. |
| Whether Herron was entitled to qualified immunity notwithstanding the claim. | Prima facie showing of violation defeats immunity. | If no constitutional violation or not clearly established, immunity applies. | Herron not entitled to qualified immunity; denial of summary judgment affirmed. |
Key Cases Cited
- Meritor Sav. Bank v. Vinson, 477 U.S. 57 (U.S. 1986) (establishes unwelcome harassment standard and objective/subjective standard)
- Harris v. Forklift Sys., 510 U.S. 17 (U.S. 1993) (severity/pervasiveness framework for hostile environment)
- Oncale v. Sundowner Offshore Servs., 523 U.S. 75 (U.S. 1998) (third prong: objective/subjective standard for harassment)
- Anderson v. Creighton, 483 U.S. 635 (U.S. 1987) (objective reasonableness inquiry for clearly established rights)
- Moring v. Ark. Dep’t of Corr., 243 F.3d 452 (8th Cir. 2001) (hostile environment can be based on pervasive conduct)
- Mukaida v. Hawaii, 159 F. Supp. 2d 1211 (D. Haw. 2001) (consensual relationship that becomes unwelcome supports claim)
- Scelta v. Delicatessen Support Servs., 89 F. Supp. 2d 1311 (M.D. Fla. 2000) (point where consensual relations become unwelcome)
- Moore v. Forrest City Sch. Dist., 524 F.3d 879 (8th Cir. 2008) (treatment of sex-discrimination claims under §1983)