Lyle v. Warner Brothers Television Productions

Amaani Lyle (plaintiff) was a writers’ assistant on the popular television comedy Friends. Before she was hired, Lyle was warned that Friends focused on sexual matters and that “the humor could get a little lowbrow in the writers’ room.” Lyle was told that her role as a writers’ assistant would include transcribing sexual jokes and dialogue for potential use in the show’s scripts. Warner Brothers Television Productions (Warner Brothers) (defendant) discharged Lyle because of problems with her typing and transcription. Lyle then filed a lawsuit, alleging that she had been subjected to a hostile work environment by three male writers during her four months of employment on the production. For instance, the writers often engaged in graphic discussions about their sexual preferences in women. One of the writers had a coloring book that depicted cheerleaders in sexual poses that he would embellish and sometimes leave on his desk or the writers’ assistants’ desks. The male writers talked about what they would like to do sexually with female cast members and made derogatory sexual comments about female cast members. The male writers bragged about their own sexual exploits and pantomimed sexual acts, including masturbation. Female writers also discussed their sexual histories to generate material for scripts. Lyle compared the environment to a junior-high locker room. Lyle did not allege that anyone on the production said anything sexually offensive about her directly to her. No one asked Lyle out on a date or sexually propositioned her. The trial court granted summary judgment to Warner Brothers, finding, as a matter of law, that Lyle could not establish that she was subjected to a hostile work environment. Lyle appealed.