From: Executive Assistants to Dr. Hodge
Hostile Work Environment Suit
September 14, 2010
Recently, our longtime client, Dr. Donald Jones, approached Dr. Hodge, the managing partner of
our law firm, with a major legal dilemma.
Dr. Jones is a co-owner, along with Joe Roberts, of
Tyler’s Sports Bar & Grill (“Tyler’s”).
One of their employees, Mandy Williams, has just filed a
lawsuit against Tyler’s and its owners.
Ms. Williams raised a number of claims in her complaint
including intentional infliction of emotional distress, hostile work environment, and retaliation,
to name a few.
Dr. Hodge has asked you to write a memorandum only addressing the
hostile work environment claim.
Dr. Jones and Mr. Roberts hired Ms. Williams one (1) year ago to work as a bartender.
Roberts was Ms. Williams’ direct supervisor.
Ms. Williams had one co-worker on her shift,
Although the space behind the bar was tight, three people could easily work behind
the bar without bumping into each other.
Nevertheless, Mr. Roberts would often brush up
against Ms. Williams.
Over the course of seven months, and several times each day, Mr. Roberts
would daily brush up against Ms. Williams’ backside when he walked behind her.
would also stand close to Ms. Williams while tending the bar and his arm would sometimes
brush up against Ms. Williams’ breasts.
Ms. Williams noticed that Mr. Roberts never brushed up
against Mr. Smith, a male bartender.
At first, Ms. Williams did not say anything to Mr. Roberts
although when Mr. Roberts would brush up against her, she would always move to make room
Additionally, at least three times, Ms. Williams heard Mr. Roberts tell a customer that
the bar did not get “hot” until Ms. Williams walked into it.