Daniels v. Pike County Commissioners, 706 F. App'x 281

Background

Pamela Daniels, a female victim-advocate/witness-coordinator in the Pike County (Ohio) prosecutor’s office, alleged sex-based hostile work environment, discriminatory termination, retaliation, and intentional infliction of emotional distress by prosecutor Rob Junk.
After attending a seminar, Junk implemented stricter office policies (five 8-hour days, time clocks, dress code, restricted computer use) and enforced them principally against female front-office employees; he also engaged in taunting conduct (e.g., popping bubble wrap, leaving browser histories visible).
Daniels complained to a deputy sheriff (Tara Tackett) and a victim’s advocate (Dominica Hannah) after an incident in which Junk displayed an AR-15 and made a joking comment; shortly thereafter Junk fired Daniels and admitted he considered her “disloyal.”
District court granted summary judgment for Junk on all claims, reasoning the harassment was not objectively severe or pervasive, termination was supported by nondiscriminatory reasons, Daniels’ reporting was too vague to be protected activity, and IIED standards were unmet.
Sixth Circuit (majority) affirmed summary judgment on hostile-work-environment, discriminatory-termination, and IIED claims but reversed as to retaliation, holding there are genuine issues of material fact on whether Daniels engaged in protected activity and whether Junk’s admission created direct evidence of retaliation.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Hostile work environment (Title VII & Ohio law)	Junk’s disparate treatment, demeaning comments, selective enforcement, and conduct (including gun incident) created an abusive environment based on sex	Actions were managerial, job-function based, intermittent, not severe or pervasive enough to alter terms/conditions of employment	Affirmed: conduct not objectively severe or pervasive under Harris/Williams standard
Discriminatory termination	Daniels was fired because of her sex; replaced by a male and Junk made anti-female remarks	Junk fired Daniels for “disloyalty,” poor performance, attitude, and statements she made to third parties—legitimate nondiscriminatory reasons	Affirmed: Daniels established prima facie case but failed to show pretext under McDonnell Douglas/Burdine
Retaliation (Title VII & Ohio law)	Daniels’ complaints to Tackett and Hannah were protected activity opposing sex discrimination; Junk admitted firing her for those statements	Junk argued Daniels’ statements were vague and not specific complaints of sex discrimination	Reversed: viewed in context, complaints were protected and Junk’s admission created a genuine dispute of material fact precluding summary judgment
Intentional infliction of emotional distress (Ohio law)	Junk’s repeated humiliations, discriminatory conduct, prank with bubble wrap, and gun display cause severe emotional distress	Conduct, while boorish, fell short of the extreme/outrageous threshold; plaintiff’s emotional harm not severe enough	Affirmed: Daniels failed to meet Ohio’s high IIED standard

Key Cases Cited

Oncale v. Sundowner Offshore Servs., 523 U.S. 75 (same-sex and nonsexual conduct can be actionable under Title VII)
Faragher v. City of Boca Raton, 524 U.S. 775 (employer liability and standards for hostile work environment)
Harris v. Forklift Sys., Inc., 510 U.S. 17 (hostile-work-environment standard: severe or pervasive; objective/subjective test)
Williams v. Gen. Motors Corp., 187 F.3d 553 (6th Cir.) (nonsexual conduct can be sex-based harassment; hostile-environment elements)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden-shifting framework for circumstantial discrimination claims)
Texas Dep’t of Cmty. Affairs v. Burdine, 450 U.S. 248 (articulation of legitimate nondiscriminatory reasons and plaintiff’s burden to show pretext)
Yazdian v. Con-Med Endoscopic Techs., Inc., 793 F.3d 634 (6th Cir.) (standards for direct vs circumstantial evidence in retaliation claims)