Williams v. CSX Transportation Co.
2011 U.S. App. LEXIS 13120
| 6th Cir. | 2011Background
- Stephanie Williams, the only black and only female clerk at CSX's Bruceton facility, alleged race- and sex-based disparate treatment and hostile environment from 2002–2004.
- Williams alleges specific incidents: feces in restroom walls/urinal, floor stripping with an inappropriate tool, mileage reimbursement denial, and vandalism to her car, with some events occurring while supervised by Ed Anderson.
- A racially charged confrontation by CSX supervisors Wingo and Magargle occurred around September 2004; Williams faced subsequent relocation to CSX’s Nashville facility.
- Two EEOC filings followed: a non-verified Charge Information Form detailing the Wingo incident and environment, and a verified Charge of Discrimination alleging discrimination/retaliation linked to the dislocation.
- District court granted summary judgment on Williams's sexually hostile environment claim for failure to exhaust; it later granted judgment as a matter of law against the race claim, deeming it not sufficiently severe or pervasive.
- The court of appeals reversed on the sexually hostile environment exhaustion issue, but affirmed the judgment against the racially hostile environment claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Williams exhausted her sexually hostile work environment claim | Williams argues Holowecki allows amendment/verification to cure defects. | CSX contends no proper charge existed for the sexually hostile environment. | Yes; the filing(s) constitute a charge. |
| Whether Williams's second filing constitutes a charge | Verified Charge of Discrimination supports exhaustion of the sexually hostile environment claim. | The verified filing does not raise a hostile-environment claim. | Yes; second filing constitutes a charge. |
| Whether the racial hostile environment claim was properly adjudicated as a matter of law | Evidence, including Wingo's remarks and disparate janitorial duties, supports a racially hostile environment. | Isolated, race-based statements and other conduct were not severe or pervasive enough. | No; insufficient to grant judgment as a matter of law; jury should decide. |
| Whether the CSX ethics hotline report was admissible | Report shows notice of harassment; not offered for truth but to prove notice. | Report is hearsay and not part of the hostile-environment framework for the promoted claims. | Admissibility rejected; report excluded as hearsay. |
Key Cases Cited
- Federal Express Corp. v. Holowecki, 552 U.S. 389 (U.S. 2008) (Holowecki tolerance for interpreting charges as requests for agency action)
- Holowecki (cited case) (internal reference), 552 U.S. 389 (U.S. 2008) (see Holowecki for 'objective observer' standard)
- Edelman v. Lynchburg College, 535 U.S. 106 (U.S. 2002) (verification requirement deference under Chevron)
- Oncale v. Sundowner Offshore Servs., Inc., 523 U.S. 75 (U.S. 1998) (establishes framework for race-based harassment analysis)
- Harris v. Forklift Sys., Inc., 510 U.S. 17 (U.S. 1993) (totality-of-the-circumstances standard for hostile environment)
- Betts v. Costco Wholesale Corp., 558 F.3d 461 (6th Cir. 2009) (totality-of-circumstances analysis; scenarios for racial hostility)
- Williams v. Gen. Motors Corp., 187 F.3d 553 (6th Cir. 1999) (considers totality of harassment and comparative evidence)
- Jackson v. Quanex Corp., 191 F.3d 647 (6th Cir. 1999) (treats §1981 and Title VII harassment standards similarly)
- Moore v. KUKA Welding Sys. & Robot Corp., 171 F.3d 1073 (6th Cir. 1999) (employer notice and response as needed for hostile environment claims)