Jane Doe v. City of Detroit, Mich., 3 F.4th 294

Plaintiff (Jane Doe), a transgender City of Detroit employee, began presenting as female while employed and received multiple harassment incidents: defaced nameplate, a gift bag with a phallic sex toy and a biblical note, and two typed threatening notes quoting Leviticus (one referencing death).
Doe reported incidents to supervisors, HR, and the Human Rights department; the city collected handwriting samples, interviewed employees, announced a zero-tolerance policy, and opened internal investigations.
Doe repeatedly requested locks/cameras and safety measures; the city installed locks and cameras months later, temporarily relocated Doe, and later moved and disciplined a coworker (Charles Allen) for unrelated Facebook conduct; police investigated later but never identified the harasser.
Doe claimed the city’s response was inadequate, alleged continued hostile treatment by supervisors, and filed EEOC/MDCR charges and suit under Title VII and Michigan’s Elliott-Larsen Civil Rights Act for hostile work environment and retaliation (failure to promote).
The district court granted summary judgment for the city; the Sixth Circuit affirmed, concluding the city’s responses were reasonably calculated to end the harassment and Doe failed to show causation for retaliation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Employer liability for coworker harassment	City failed to take prompt/adequate corrective action for repeated harassment	City promptly investigated, took handwriting samples, interviewed staff, announced zero-tolerance, later installed locks/cameras and took personnel steps	Employer response was reasonable; no liability under coworker standard
Adequacy/timing of investigations and security measures	City should have involved police/building security sooner and installed locks/cameras immediately	City initiated prompt internal investigations, contacted police later, and installed locks/cameras within days of the May note	Delay was not unreasonable; victim’s dissatisfaction insufficient to show indifference
Actions against identified suspect (Allen)	City failed to investigate or discipline Allen after Doe identified him	City disciplined/moved Allen when misconduct surfaced and temporarily relocated Doe; no further incidents followed	Moving/discipline and security measures were reasonably calculated to stop harassment
Retaliation (failure to promote / adverse treatment)	Denied promotion and suffered retaliatory hostility because she filed complaints	Hiring decision was made solely by CFO; no evidence linking complaints to hiring or other adverse acts	No causal evidence; temporal gap and speculation insufficient—summary judgment affirmed

Randolph v. Ohio Dep’t of Youth Servs., 453 F.3d 724 (6th Cir. 2006) (elements for hostile work environment claim under Title VII)
Hafford v. Seidner, 183 F.3d 506 (6th Cir. 1999) (employer liable for coworker harassment if it knew or should have known and failed to take prompt, appropriate corrective action)
Clark v. United Parcel Serv., Inc., 400 F.3d 341 (6th Cir. 2005) (distinguishing vicarious liability for supervisors from knowledge-based liability for coworkers)
Hawkins v. Anheuser-Busch, Inc., 517 F.3d 321 (6th Cir. 2008) (employer response adequate if reasonably calculated to end harassment)
Jackson v. Quanex Corp., 191 F.3d 647 (6th Cir. 1999) (employer’s failure to act can show indifference; remedy must fit severity/persistence)
Smith v. Rock-Tenn Servs., Inc., 813 F.3d 298 (6th Cir. 2016) (employer’s total inaction may be unreasonable where known perpetrator and prior warnings)
Blankenship v. Parke Care Ctrs., Inc., 123 F.3d 868 (6th Cir. 1997) (complainant cannot dictate employer’s chosen measures; employer liable if response manifests indifference)
Bostock v. Clayton Cnty., 140 S. Ct. 1731 (U.S. 2020) (discrimination against transgender persons is discrimination based on sex)