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DeAngelis v. El Paso Municipal Police Officers Association

51 F.3d 591 (1995)

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DeAngelis v. El Paso Municipal Police Officers Association

United States Court of Appeals for the Fifth Circuit
51 F.3d 591 (1995)

  • Written by Galina Abdel Aziz , JD

Facts

Sylvia DeAngelis (plaintiff) became the first female sergeant at the El Paso Police Department in October 1987. An anonymous writer, who was known as R. U. Withmi, satirized DeAngelis in The Silver Badge, a newsletter distributed by the El Paso Municipal Police Officers Association (police association) (defendant). Between November 1987 and February 1990, R. U. Withmi derogatorily referred to policewomen and angered more than 24 female police officers. R.U. Withmi called DeAngelis a “dingy woman” and ridiculed her “E-I-E-I-O” complaint, which referred to her Equal Employment Opportunity Commission (EEOC) complaint. The female police officers asked the police chief to stifle R. U. Withmi, but the police chief had no direct authority over the police association. Additionally, the police association refused to require R. U. Withmi to unmask himself. The female police officers were given the opportunity to respond to R. U. Withmi, but none of them did. DeAngelis sued the police association under Title VII of the Civil Rights Act of 1964.

Rule of Law

Issue

Holding and Reasoning (Jones, J.)

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