Barnes v. Train

Barnes initially filed the case in the District Court for the District of Columbia. The court decided that the sexual harassment Barnes faced caused her to lose her job, but that this was not illegal because it was not solely due to gender: she was fired "not because she was a woman, but because she refused to engage in a sexual affair with her supervisor." Therefore, the court reasoned, Barnes had not faced gender discrimination in violation of Title VII of the Civil Rights Act of 1964. This court gave a summary judgement for her employer and denied her claim. In Barnes, the appeals court found that the supervisor's quid pro quo harassment was not applied to male employees. Thus Barnes' supervisor discriminated by gender, which was just as key to his punishment of Barnes as her lack of cooperation, making his actions illegal. The appeals court in Barnes also found that companies are liable for not stopping sexual harassment if they know it is being conducted by supervisors. == Significance ==

Barnes helped set the precedent that sexual harassment leading to tangible employment loss was sex discrimination covered by Title VII, but it wasn't until Bundy v. Jackson (1981) that workplace sexual harassment, even without tangible employment loss, could constitute illegal discrimination by sex. == References ==