Straka v. Francis

Executive Flight Management/Trans American Charter, Ltd. (Executive Flight) (defendant) hired and trained three flight attendants (plaintiffs) to work on charter flights that Executive Flight had contractually agreed to provide to the Florida Marlins, a professional baseball team. The attendants were repeatedly subjected to sexual harassment that was either committed by or condoned by Executive Flight’s management. The harassment included sexual innuendoes, suggestive comments about the flight attendants’ appearance, references to sexual activity, and derogatory comments about the attendants’ ages. Hours before a charter flight was scheduled to take off with the Marlins baseball team, all three flight attendants quit. The attendants sued Executive Flight and several individuals for sex and age discrimination under Title VII of the Civil Rights Act of 1964 and the Age Discrimination in Employment Act (ADEA). The attendants alleged that they had been constructively discharged because the hostile work environment had forced them to quit. Executive Flight moved to dismiss the individual defendants, arguing that the federal discrimination statutes did not allow claims against individuals. Executive Flight also filed counterclaims against the flight attendants, claiming that the attendants were liable for (1) breach of contract or promissory fraud for quitting before completing the scheduled flight and (2) tortious interference with the company’s contract with the Marlins. The flight attendants moved for summary judgment on the counterclaims.