Haughton v. JA-Co Foods, Inc., 1:20-cv-00241

Hired by Sonic in Aberdeen in mid-November 2019; worked ~6 weeks before termination.
Allegations against assistant manager Eric Ellis: repeatedly sang sexually suggestive songs, called plaintiff “baby” twice, touched her hand several times, and on Dec. 22, 2019 allegedly "humped" her from behind for ~3 seconds while she bent over a trash can.
Plaintiff reported the Dec. 22 incident to GM Alesha Gardner and a corporate rep; Gardner investigated, found allegations unsubstantiated, but instructed that Ellis not work with plaintiff.
On Dec. 30, 2019 plaintiff was involved in a heated encounter with shift lead Tay (Shehaqueeka Randle) and Alexis Ellis (Eric’s daughter); Sonic investigated and terminated plaintiff for insubordination/abusive conduct.
Plaintiff sued under Title VII (hostile work environment and retaliation) and for common-law assault (based on Dec. 30 episode). Sonic moved for summary judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Hostile work environment (Title VII)	Ellis’s repeated verbal conduct, unwanted touching, and the Dec. 22 physical contact created an objectively and subjectively hostile environment	Conduct was sporadic/insufficiently severe; employer investigated promptly so no liability	Court denied summary judgment: triable facts exist; Dec. 22 incident especially severe and Ellis plausibly a supervisor so vicarious liability applies (employer respondeat superior)
Retaliation (Title VII)	Termination ~8 days after reporting Ellis shows causal connection; termination was pretext for retaliation	Termination was lawful: internal investigation found plaintiff instigated Dec. 30 incident and violated policy	Court denied summary judgment: plaintiff made prima facie showing (timing + report), employer articulated legitimate reason, and genuine fact issues exist on pretext
Common-law assault (vicarious liability)	Tay and Alexis assaulted plaintiff on Dec. 30; Sonic liable because acts occurred in the scope of employment	The alleged assault was outside scope of employment and not connected to job duties; employer policy forbids harassment	Court granted summary judgment for Sonic: no evidence the employees’ threatening conduct was within scope of employment; assault claim dismissed with prejudice

Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment standard)
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 (objective and subjective hostile-work-environment test)
Nat’l R.R. Passenger Corp. v. Morgan, 536 U.S. 101 (discrete acts vs. hostile-environment claims)
West v. City of Houston, 960 F.3d 736 (Fifth Circuit hostile-work-environment analysis)
EEOC v. WC&M Enters., Inc., 496 F.3d 393 (single severe incident can suffice under totality-of-circumstances)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden-shifting framework for discrimination/retaliation)
Brown v. Wal-Mart Stores East, L.P., 969 F.3d 571 (but-for causation in Title VII retaliation; timing for prima facie showing)
Watts v. Kroger Co., 170 F.3d 505 (supervisor-created hostile work environment and employer vicarious liability)