Butler v. Drive Automotive Industries of America, Inc.

793 F.3d 404 (2015)

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Butler v. Drive Automotive Industries of America, Inc.

United States Court of Appeals for the Fourth Circuit
793 F.3d 404 (2015)

Facts

Brenda Butler (plaintiff) was hired by ResourceMFG, a temporary-staffing agency, to work at a factory operated by Drive Automotive Industries of America, Inc. (Drive) (defendant). Drive oversaw certain aspects of Butler’s employment, including her work schedule and training, and was responsible for her day-to-day supervision. ResourceMFG issued uniforms and parking spots and was ultimately responsible for discipline and terminations. Butler claimed that John Green, one of her Drive supervisors, sexually harassed her. Butler reported Green’s conduct to representatives of ResourceMFG and Drive, and they took no action. After Butler reported another inappropriate encounter with Green, Drive requested that ResourceMFG terminate Butler’s employment, and ResourceMFG did so. Butler filed suit against Drive for sexual harassment under Title VII of the Civil Rights Act of 1964 (Title VII). The district court concluded that ResourceMFG was Butler’s sole employer and entered summary judgment for Drive. Butler appealed.

Rule of Law

Issue

Holding and Reasoning (Floyd, J.)

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