Equal Employment Opportunity Commission v. KarenKim, Inc.

KarenKim, Inc. (defendant) was a New York grocery store owned by Karen Connors. Connors had a long-term romantic relationship with the store’s manager, Allen Manwaring. For years, Manwaring physically and verbally sexually harassed the store’s teenage, female employees. Despite employee complaints, Connors did nothing to address the situation. Eventually, the Equal Employment Opportunity Commission (EEOC) (plaintiff) sued KarenKim under Title VII of the Civil Rights Act of 1964 (Title VII), alleging that KarenKim had subjected female employees to unlawful sexual harassment. The jury held in the EEOC’s favor, awarding damages to 10 employees. By the end of trial, Manwaring no longer worked at KarenKim. However, he maintained his romantic relationship with Connors and was a produce supplier for the store. The EEOC moved to amend the judgment to include a 10-year injunction that: (1) prohibited KarenKim from maintaining a hostile work environment or retaliating against employees reporting Title VII violations, (2) prohibited KarenKim from rehiring Manwaring, (3) prohibited KarenKim from allowing Manwaring to enter the store, (4) required KarenKim to provide notices that Manwaring was barred from the store, (5) required KarenKim to hire an independent monitor to review its employment practices and complaints, and (6) authorized the EEOC to monitor KarenKim’s compliance with the injunction. The district court denied injunctive relief, concluding an injunction was not necessary because Title VII violations were unlikely to recur given that Manwaring no longer worked at the store and KarenKim had adopted an antidiscrimination policy. The EEOC appealed.