Great American Federal Savings & Loan Association v. Novotny

442 U.S. 366, 99 S. Ct. 2345 (1979)

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Great American Federal Savings & Loan Association v. Novotny

United States Supreme Court
442 U.S. 366, 99 S. Ct. 2345 (1979)

Facts

John Novotny (plaintiff) was a director and loan officer with Great American Federal Savings & Loan Association (Great American). Novotny discovered that Great American’s board of directors had intentionally discriminated against female employees by denying female employees equal employment opportunities. After Novotny protested the discriminatory policy and spoke out in support of Great American’s female employees, he was fired. Novotny brought a Title VII employment-discrimination action against Great American and sought damages under 42 U.S.C. § 1985(3), arguing that he had been injured as a result of Great American’s hostile conspiracy to discriminate against female employees. The district court granted Great American’s motion to dismiss, holding that, as a matter of law, the board of directors of a single corporation could not engage in a conspiracy. Novotny appealed. The Third Circuit reversed, holding that intracorporate conspiracies to engage in sex-based discrimination in violation of Title VII could be redressed using § 1985(3)’s remedial framework. Great American appealed.

Rule of Law

Issue

Holding and Reasoning (Stewart, J.)

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