Williams v. Spartan Communications
United States Court of Appeals for the Fourth Circuit
2000 U.S. App. LEXIS 5776 (March 30, 2000)
Veneal Williams (plaintiff) worked for Spartan Communications, Incorporated (Spartan) (defendant) selling advertising. Allegedly, her immediate supervisor, Mitchell Maund, sexually assaulted her on three separate occasions during business trips between 1992 and 1995. Williams reported the assaults to two Spartan managers, Greg Rose and Donna Groothedde, on May 24, 1995. She reported that one of the assaults occurred in Williams’s van while watching an R-rated movie that Maund had instructed that they watch together. Rose, Groothedde, and Spartan’s vice president and general manager, Jack West, met with Maund on May 25. Maund admitted to renting the movie. He resigned later that day as a result of the meeting with the Spartan managers. Spartan had an antiharassment policy in place, but Maund did not recall any training or discussion regarding the policy. Maund was close with several managers at Spartan. Several managers had made sexually explicit or misogynistic comments in the past to no correction or discipline. Williams resigned from her job at Spartan, citing the distress of continued sexual harassment. Williams brought a hostile-environment claim against Spartan. The district court granted summary judgment in favor of Spartan, finding that Spartan had established an affirmative defense. Williams appealed.
Rule of Law
Holding and Reasoning (Motz, J.)
Dissent (Wilkinson, C.J.)
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