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Oncale v. Sundowner Offshore Services, Inc.

United States Supreme Court
523 U.S. 75 (1998)


Facts

In October 1991, Joseph Oncale (plaintiff) was working for Sundowner Offshore Services, Inc. (Sundowner) (defendant) on an oilrig in the Gulf of Mexico. Oncale was part of an eight-man crew, which included John Lyons, Danny Pippen, and Brandon Johnson (defendants). Lyons and Pippen had supervisory authority over Oncale. On multiple occasions, Lyons, Pippen, and Johnson directed toward Oncale humiliating verbal abuse of a sexual nature. Pippen and Johnson subjected Oncale to physical sexual assault, and Lyons threatened to rape Oncale. When Oncale reported this abuse to a safety supervisor, the supervisor was dismissive and also made reference to Oncale’s sexual orientation. Eventually, Oncale quit his job, explicitly citing the sexual harassment and verbal abuse as his reasons for leaving. Oncale sued Sundowner, Lyons, Pippen, and Johnson, alleging sex discrimination in violation of Title VII of the Civil Rights Act of 1964 (Title VII), 42 U.S.C. § 2000e et seq. A district court granted summary judgment to the defendants based on its conclusion that there was no cause of action under Title VII, because Oncale and his co-workers were members of the same sex. The United States Court of Appeals for the Fifth Circuit affirmed. Oncale petitioned for review by the United States Supreme Court.

Rule of Law

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Issue

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Holding and Reasoning (Scalia, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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