Reeves V. C.H. Robinson Worldwide, Inc.
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''Reeves v CH Robinson Worldwide, Inc'', 5 No. 07-10270 (11th Cir. January 20, 2010) is a
US labor law United States labor law sets the rights and duties for employees, labor unions, and employers in the US. Labor law's basic aim is to remedy the " inequality of bargaining power" between employees and employers, especially employers "organized in ...
case under Title VII of the Civil Rights Act of 1964 heard before the
United States Court of Appeals for the Eleventh Circuit The United States Court of Appeals for the Eleventh Circuit (in case citations, 11th Cir.) is a federal appellate court over the following U.S. district courts: * Middle District of Alabama * Northern District of Alabama * Southern District ...
which ruled that a
hostile work environment In United States labor law, a hostile work environment exists when one's behavior within a workplace creates an environment that is difficult or uncomfortable for another person to work in, due to illegal discrimination. However, a working environm ...
can be created in a workplace where sexually explicit language and
pornography Pornography (colloquially called porn or porno) is Sexual suggestiveness, sexually suggestive material, such as a picture, video, text, or audio, intended for sexual arousal. Made for consumption by adults, pornographic depictions have evolv ...
are present. A hostile workplace may exist even if it is not targeted at any particular employee.


Facts

Ms. Reeves was the only woman working in her area as a transportation
sales representative Sales are activities related to selling or the number of goods sold in a given targeted time period. The delivery of a service for a cost is also considered a sale. A period during which goods are sold for a reduced price may also be referred ...
in the
Birmingham, Ala. Birmingham ( ) is a city in the north central region of Alabama, United States. It is the county seat of Jefferson County. The population was 200,733 at the 2020 census, making it the second-most populous city in Alabama, and estimated at 1 ...
, office of C.H. Robinson, an
Eden Prairie, Minnesota Eden Prairie is a city in Hennepin County, Minnesota, United States. It had a population of 64,198 at the 2020 census, making it the 16th-largest city in Minnesota. The city is adjacent to the north bank of the Minnesota River, upstream fro ...
-based transportation services firm. In her
lawsuit A lawsuit is a proceeding by one or more parties (the plaintiff or claimant) against one or more parties (the defendant) in a civil court of law. The archaic term "suit in law" is found in only a small number of laws still in effect today ...
she claimed that "sexually offensive language permeated the work environment" from both her co-workers and her supervisor. Sexually explicit radio programming played on a daily basis and when she complained about it she was told it was up to her to play her own radio stations. When she did change the channel others would change it back. She resigned in 2004 and filed a complaint in 2006, claiming that the sexually offensive language created a hostile work environment. A lower court dismissed her case granting summary judgment to her employer. Reeves appealed.


Judgment

The
United States Court of Appeals for the Eleventh Circuit The United States Court of Appeals for the Eleventh Circuit (in case citations, 11th Cir.) is a federal appellate court over the following U.S. district courts: * Middle District of Alabama * Northern District of Alabama * Southern District ...
ruled that a
hostile work environment In United States labor law, a hostile work environment exists when one's behavior within a workplace creates an environment that is difficult or uncomfortable for another person to work in, due to illegal discrimination. However, a working environm ...
can be created in a workplace where sexually explicit language and
pornography Pornography (colloquially called porn or porno) is Sexual suggestiveness, sexually suggestive material, such as a picture, video, text, or audio, intended for sexual arousal. Made for consumption by adults, pornographic depictions have evolv ...
are present. A hostile workplace may exist even if it is not targeted at any particular employee.


See also

*
US labor law United States labor law sets the rights and duties for employees, labor unions, and employers in the US. Labor law's basic aim is to remedy the " inequality of bargaining power" between employees and employers, especially employers "organized in ...


Notes

{{reflist Harassment case law 2010 in United States case law Sexual harassment in the United States United States employment discrimination case law United States gender discrimination case law