Faragher v. City of Boca Raton
Introduction
The discussed case is Faragher v. City of Boca Raton, which was decided by the U.S. Supreme Court on June 26, 1998. It implied applying the Title VII of the Civil Right Act of 1964, saying that any employer may be liable for supervisory employees creating a hostile work environment via sexual harassment (Faragher v. City of Boca Raton, 1998). The Supreme Court ruled that the employer had a chance to make an affirmative defense (Faragher v. City of Boca Raton, 1998). In such a way, the selected case involves civil rights issues and their consideration.
Beth Ann Faragher is the complainant of the case, who worked for the City of Boca Raton, Florida, as a lifeguard. She experienced harassment and offensive sexual comments from her male supervisors (Faragher v. City of Boca Raton, 1998). For this reason, she filed a suit under Title VII, claiming that workers cultivated a hostile work environment through their actions (Faragher v. City of Boca Raton, 1998). Boca Raton city became associated with the cost of the process and possible damages.
Case Outline
Title
Faragher v. City of Boca Raton – 524 U.S. 775, 118 S. Ct. 2275 (1998)
Facts of the Case
Ann Faragher is the complainant of the case, who worked for the City and experienced sexual harassment from David Silverman and Bill Terry. She reported that they performed the following undesired actions: offensive speeches, commenting, jokes, touching, joking, and hints with specific sexual context. Her female colleagues reported they had similar experiences interacting with Terry and Silverman. It proved the topicality of Faragher’s complaint and the severity of the case, and regular violations of basic human rights were observed. Ann Faragher claimed that comments, actions, gestures, and offensive words are unacceptable as they violate her fundamental rights regulated by the Civil Rights Act of 1964 and discriminate against her regarding gender (Faragher v. City of Boca Raton, 1998). The state should also be responsible for its employees. The District Court ruled that the city was responsible for Terry and Silverman’s misconduct. The Court of Appeals supported the ruling, as Terry and Silverman violated employment terms (Faragher v. City of Boca Raton, 1998). Boca Raton could not hold responsibility for negligence in being unable to eliminate such actions (Faragher v. City of Boca Raton, 1998).
History of the Case
The federal district court agreed with Faragher’s arguments and ruled in her favor (Faragher v. City of Boca Raton, 1998). The City could litigate further (Faragher v. City of Boca Raton, 1998). The Eleventh Circuit Court of Appeals refused to impose liability on the City (Faragher v. City of Boca Raton, 1998). The U.S. Supreme court overturned the previous ruling and agreed with the federal district court’s conclusion (Faragher v. City of Boca Raton, 1998). The case resulted in the emergence of the concept of the Faragher affirmative disease (Parry, 2020). It is used by employers to avoid vicarious liability linked to harassment claims against employees hired by them (O’Brien & Silverstein, 2020). Employers should create an environment favorable for employees and helping to avoid sexual harassment (Wasserman, 2018).
Legal Questions
Following the Title VII of the Civil Rights Act of 1964 linked to the sexually hostile work environment created by supervisors, can an employer City be held vicariously liable for its employees’ actions? (Faragher v. City of Boca Raton, 1998).
Decision on Holdings
The Court supported Faragher’s claim and ruled that Boca Raton City should be held liable for the sexual harassment associated with its employees. Most arguments offered by the complainant were accepted and used to make a final conclusion. At the same time, the Court stated that the City should not be considered liable for failing to prevent sexual abuse or gender discrimination scenarios and situations (Faragher v. City of Boca Raton, 1998).
Verdict and Opinion
Justice David Souter offered the opinion, assuming that the case can be viewed as the opposition between the traditional view on discriminative actions made by supervisors, and a new perspective, stating that such actions should be controlled by employers and considered as a part of their responsibility (Faragher v. City of Boca Raton, 1998). Justice Thomas offered the dissenting option, saying the employer cannot be considered vicariously liable if employees cultivate inappropriate working conditions and fail to follow the major rules (Faragher v. City of Boca Raton, 1998). Rehnquist, Stevens, O’Connor, Kennedy, Ginsburg, and Breyer supported Souter’s opinion (Faragher v. City of Boca Raton, 1998). Scalia was the only justice who supported the dissent (Faragher v. City of Boca Raton, 1998).
Conclusion
The Court ruled that the employer should be considered responsible following the Title VII of the Civil Rights Act of 1964. The City was not able to prove that it tried to control its supervisors’ behaviors to guarantee that women could feel safe and enjoy their fundamental civil rights. The conclusion created the basis for other citizens to address the Court attempting to protect their basic rights and ensure there are no harassment or sexual abuse cases in their work (Parry, 2020).
References
Faragher v. City of Boca Raton, 524 U.S. 775 (1998)
O’Brien, D., & Silverstein, G. (2020). Constitutional law and politics: Civil rights and civil liberties (11th ed.). W. W. Norton & Company.
Parry, J. (2020). Cases and problems in civil rights litigation: State, federal, and international perspectives. Semaphore Press.
Wasserman, H. (2018). Understanding civil rights litigation (2nd ed.). Carolina Academic Press.