Henson v. City of Dundee

Barbara Henson (plaintiff) was a police dispatcher in Dundee, Florida (defendant), in 1975. While working at the five-officer police department, Henson was sexually harassed by the chief of police, John Sellgren. Sellgren made demeaning sexual inquiries and requests to Henson and her female coworker, Dicks. Henson complained to the city manager, Jane Eden, who did not take any action. Sellgren placed Henson on a two-day suspension for violating the prohibition on eating food in the dispatch room, which was not typically enforced. Henson interpreted the suspension as a warning from Sellgren that she should accept his requests for sex or risk termination. Additionally, Sellgren told Henson that if she complied with his sexual requests, then he would help her gain approval from Eden to enter the police academy. During the two years Henson worked at the department, two male dispatchers were sent to the police academy. Henson resigned on January 28, 1977, out of the fear that she would be fired if she did not comply with Sellgren’s requests. Henson sued Dundee in a federal district court. Henson alleged that Title VII of the Civil Rights Act of 1964 (Title VII) was violated because she was sexually harassed, constructively discharged, and prevented from attending the police academy. At trial, Eden testified that Henson was qualified to enter the police academy and that Eden would have accepted Henson if Sellgren had communicated Henson’s interest. The district court ruled for Dundee. Henson appealed.