Ferris v. Delta Air Lines
United States Court of Appeals for the Second Circuit
277 F.3d 128 (2001)
- Written by Angela Patrick, JD
Facts
Two flight attendants who worked for Delta Air Lines, Inc. (Delta) (defendant) reported to Delta that fellow flight attendant Michael Young had raped them, and a third flight attendant reported that Young had become threatening and aggressive when she refused to have dinner with him. Two of the victims identified Young by name but were uncomfortable making written reports. The third victim wanted to make a written report, but the Delta supervisor told her to not write a report or tell anyone about the matter. Delta never officially responded to any of the information. Then, during a crew layover in Italy, Young drugged and raped fellow flight attendant Penny Ferris (plaintiff) in his hotel room in a manner almost identical to that described in one of the earlier reports. After the incident, Ferris was afraid to be at work where she might encounter Young. As a result, Ferris suffered anxiety attacks at work, sought psychiatric help, and took antidepressants. However, Ferris was hesitant to report the rape. When Ferris made an official report weeks later, Young was suspended and eventually resigned. Ferris brought two hostile-work-environment claims against Delta, one for the work environment in Young’s hotel room and one for the work environment on flights after the incident, while Young still worked for Delta. The district court dismissed Ferris’s claims, and Ferris appealed.
Rule of Law
Issue
Holding and Reasoning (Leval, J.)
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