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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 United States. Labor law's basic aim is to remedy the "inequality of bargaining power" between employees and employers, especially employers "org ...
case under
Title VII of the Civil Rights Act The Civil Rights Act of 1964 () is a landmark civil rights and United States labor law, labor law in the United States that outlaws discrimination based on Race (human categorization), race, Person of color, color, religion, sex, and nationa ...
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 court with appellate jurisdiction over the following U.S. district courts: * Middle District of Alabama * Northern District of Alabama * ...
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. Common complaints in sexu ...
can be created in a workplace where sexually explicit language and
pornography Pornography (often shortened to porn or porno) is the portrayal of sexual subject matter for the exclusive purpose of sexual arousal. Primarily intended for adults,
are present. A
hostile workplace 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. Common complaints in sexua ...
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. The seller, or the provider of the goods or services, completes a sale in r ...
in the
Birmingham, Ala. Birmingham ( ) is a city in the north central region of the U.S. state of Alabama. Birmingham is the seat of Jefferson County, Alabama's most populous county. As of the 2021 census estimates, Birmingham had a population of 197,575, down 1% from ...
, office of C.H. Robinson, an
Eden Prairie, Minnesota Eden Prairie is a city southwest of downtown Minneapolis in Hennepin County and the List of cities in Minnesota, 16th-largest city in the U.S. state, State of Minnesota, United States. As of the 2020 United States census, 2020 census, it has a ...
-based transportation services firm. In her
lawsuit - A lawsuit is a proceeding by a party or parties against another in the civil court of law. The archaic term "suit in law" is found in only a small number of laws still in effect today. The term "lawsuit" is used in reference to a civil actio ...
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 court with appellate jurisdiction over the following U.S. district courts: * Middle District of Alabama * Northern District of Alabama * ...
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. Common complaints in sexu ...
can be created in a workplace where sexually explicit language and
pornography Pornography (often shortened to porn or porno) is the portrayal of sexual subject matter for the exclusive purpose of sexual arousal. Primarily intended for adults,
are present. A
hostile workplace 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. Common complaints in sexua ...
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 United States. Labor law's basic aim is to remedy the "inequality of bargaining power" between employees and employers, especially employers "org ...


Notes

{{reflist United States labor case law 21st century in United States case law 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