Wendy Jo Brown v. William J. Perry, Secretary of Defense

How later courts described this case

• holding that supervisors who violated the employer’s directive that all sexual harassment be reported nonetheless acted reasonably because they (1) “were confronted with a victim who has continuing to work effectively and ... who reported a single incident of harassment perpetrated by a supervisory employee with whom she would have very limited future contact”; (2) “offer[ed] immediate unconditional support to the victim,” (3) suggested that the victim speak with an Equal Employment Opportunity officer; and (4) declined to report the victim’s sexual harassment complaint only after she requested that they not pursue the matter
• stating that an employer is entitled to assert the affirmative defense where there is no evidence that the plaintiff suffered a tangible employment action at the “hands” of the alleged harasser because the alleged harasser “simply took no part in any decision to hire, fire, discharge, transfer or reassign [plaintiff], or in any way to alter her employment benefits”
• finding that the defendant employer took reasonable actions to correct an employee’s sexually harassing behavior in part because of the restraining order on the alleged harasser, the employer’s prompt investigation of the alleged harasser, and the employer’s support for the employee who allegedly was harassed
• concluding that no tangible employment action was taken when the alleged harasser "took no part in any decision to hire, fire, discharge, transfer, or reassign [the subordinate], or in any way to alter her employment benefits"

Written by the judges who cited it.