Bundy v. Jackson
United States Court of Appeals for the District of Columbia Circuit
641 F.2d 934 (1981)
Sandra Bundy (plaintiff) was a vocational-rehabilitation specialist at the District of Columbia Department of Corrections (agency) who filed suit against her former coworker and current supervisor, Director Delbert Jackson (defendant), in his official capacity for sexual harassment committed by Jackson and by other supervisors. The United States District Court for the District of Columbia found that sexual intimidation was a normal condition of employment at the agency. Bundy was subjected to repeated sexual propositions by supervisors Arthur Burton and James Gainey, as well as Jackson himself. When Bundy reported the conduct of Burton and Gainey to their supervisor, Lawrence Swain, Swain told Bundy that any man in his right mind would want to rape her. Burton also began to criticize Bundy’s supposed malingering and poor performance, even though she had never received these complaints before. Other employees besides Bundy had also been repeatedly harassed. Despite the finding of normalized sexual harassment, the district court denied Bundy any relief, finding that Bundy’s rejection of sexual advances had not resulted in any supervisors taking action against her. Bundy appealed.
Rule of Law
Holding and Reasoning (Wright, C.J.)
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