holding “to prevail on a claim of hostile work environment based on gender discrimination, the plaintiff must establish that the abuse was based on her gender. . . . The harassing conduct need not be motivated by sexual desire, however, so long as it was motivated by gender.” (internal citations and quotation marks omitted)
How later courts described this case
- holding “to prevail on a claim of hostile work environment based on gender discrimination, the plaintiff must establish that the abuse was based on her gender. . . . The harassing conduct need not be motivated by sexual desire, however, so long as it was motivated by gender.” (internal citations and quotation marks omitted)
- holding, in Title VII context, that "[cjlose temporal proximity between the plaintiffs protected action and the employer's adverse employment action may in itself be sufficient to establish the requisite causal connection between a protected activity and retaliatory action.”
- stating that that “a rational juror could permissibly infer that [an] entire alleged pattern of harassment . .. was motivated by . ... gender, even though some of the harassment was not facially sex-based” where there was at least some “overtly sexual” harassment
- finding plaintiff established retaliatory hostile work environment claim based on evidence that she was repeatedly summoned by human resources to unnecessary meetings, was given no work, and was constantly yelled at by her new supervisor
Written by the judges who cited it.
The opinion
09-1859-cv
Kaytor v. Electric Boat Corp.