Burlington Northern & Santa Fe Railway Co. v. White

Sheila White (plaintiff) was the only female employee in the Maintenance of Way department of Burlington Northern & Santa Fe Railway Company (Burlington) (defendant). As a track laborer, White was assigned to operate the forklift, which was one of the easier and more coveted duties of that position. In September 1997, White complained to Burlington that her immediate supervisor, Bill Joiner, had told her that women should not work in the Maintenance of Way department and had made inappropriate comments in the presence of her male colleagues. Burlington conducted an internal investigation and ultimately suspended Joiner for 10 days. White was subsequently advised that she would no longer operate the forklift, due to complaints by White’s coworkers that a more senior man should operate the forklift. In December 1997, after a disagreement with another supervisor, White was suspended indefinitely without pay for insubordination. Pursuant to internal grievance procedures, Burlington found that White had not been insubordinate. Burlington reinstated White and awarded White back pay for her suspension. White filed complaints with the Equal Employment Opportunity Commission, alleging that White’s reassignment and suspension constituted retaliation by Burlington for her complaint against Joiner. White later sued Burlington in district court, alleging retaliation in violation of Title VII of the Civil Rights Act of 1964 (Title VII), 42 U.S.C. § 2000e et seq. The jury found that White had suffered a materially adverse change in the terms and conditions of her employment, and awarded White compensatory damages. The court of appeals affirmed. The United States Supreme Court granted certiorari.