Do Exactly The Same Format For Both Case Analyses, Just Chan ✓ Solved
Do Exactly Same Format For Both Case Analysis Just Change The Wording
Do Exactly Same Format For Both Case Analysis Just Change The Wording
DO EXACTLY SAME FORMAT FOR BOTH CASE ANALYSIS JUST CHANGE THE WORDING. FOR THE RULE PART: COPY PASTE IT AS IT IS. Burlington Northern and Santa Fe Railroad Co. vs. White
Facts About Case: Shiela White was the only woman working in a certain department at Burlington Northern & Santa Fe Railway Company’s Tennessee Yard. White complained that her supervisor, Bill Joiner, was telling her that women should not be working that certain department.
Joiner was disciplined and White was reassigned to “track laborer” tasks, a step down from her previous position in the department as a forklift operator. White filed a first complaint to the Equal Employment Opportunity Commission (EEOC). White then filed a second complaint to the EEOC when her new supervisor, Percy Sharkey, suspended her without pay claiming insubordination by White. The case was investigated and she was reappointed into her position and given her missed salary. She then filed a Title VII action against Burlington claiming that their actions amounted to unlawful retaliation and therefore were in violation of Title VII.
The jury found in her favor and the appeal court also affirmed the decision of the District Court in White’s favor of both retaliation claims. Burlington appealed to the U.S. Supreme Court. Issue: Were Burlington’s actions reasonable or in violation of Title VII? Or would a reasonable employee find Burlington’s actions materially adverse and therefore file a claim of discrimination?
Rule: “The anti-retaliation provision seeks to secure that primary objective by preventing an employer from interfering (through retaliation) with an employee’s efforts to secure or advance enforcement of the Act’s basic guarantees… “The anti-retaliation provision seeks to prevent harm to individuals based on what they do, i.e. their conduct… “An employer can effectively retaliate against an employee by taking action not directly related to his employment of by causing him harm outside the workplace…”
Application: Burlington had to show that a reasonable employee would have found the action actually harmful in their development by showing how it would have dissuaded them from making a charge of discrimination. Her demotion from forklift operator to track laborer was substantial since the track labor duties are more arduous and dirtier. Since White’s forklift operator position was prestigious and required more qualifications, the male employee’s resented her and retaliated. The court reasonably concluded that her reassignment would have been materially adverse to a reasonable employee.
Conclusion: The U.S. Supreme Court affirmed the decision of the Court of Appeals.
Sample Paper For Above instruction
The case of Burlington Northern and Santa Fe Railroad Co. v. White underscores the significance of understanding the legal boundaries of employment retaliation under Title VII of the Civil Rights Act of 1964. This legal dispute revolves around whether the employer’s actions constituted lawful employment decisions or unlawful retaliation against an employee for engaging in protected activity.
Shiela White, as the sole woman in her department, became a focal point of discrimination due to her gender and her complaints to the EEOC. Her initial complaint against her supervisor, Bill Joiner, was based on sexist remarks implying women should not work in her department. After her complaints, she was demoted and reassigned to less desirable tasks, which constituted a potential adverse employment action. White’s subsequent suspension by her new supervisor, Percy Sharkey, without pay for alleged insubordination amplified her claims of retaliation. The legal question centered on whether these actions were reasonable management decisions or whether they were retaliatory and thus unlawful under Title VII.
According to the legal rule cited, anti-retaliation provisions aim to prevent employer behaviors that interfere with an employee's efforts to pursue rights under the act. Specifically, employers should avoid actions that are materially adverse, which could dissuade a reasonable employee from asserting their rights. In this case, White’s demotion and suspension qualify as materially adverse because they impacted her employment status and potentially her future prospects.
Applying the rule, the court examined whether a reasonable employee would view the employer’s actions as harmful enough to deter further claims of discrimination. The court found her demotion to be significant, as it involved a shift from a prestigious and qualified role to a less favorable position, which could discourage employees from filing grievances. The court also considered the context—White's complaints and the employer's response—highlighting a pattern of retaliation.
The legal conclusion affirmed that Burlington’s actions were inconsistent with Title VII’s protections against retaliation. The Supreme Court’s decision reinforced that employers should not retaliate against employees in a manner that is materially adverse, which could include demotions or suspensions due to protected activity. This case solidified the understanding that retaliation claims must consider whether an employee reasonably perceives the employer’s actions as harmful enough to deter others from asserting their rights.
In essence, the case emphasizes the importance of clear boundaries for employer conduct regarding protected activities and demonstrates that even managerial decisions that might seem justified on their face can be deemed unlawful retaliation if they deter protected conduct.
The decision has broader implications for employment law, underscoring that any adverse employment action motivated by retaliatory intent violates Title VII. Employers must navigate workplace discipline carefully to avoid unfair retaliatory practices that can result in legal and financial consequences.
References
- Burkhauser, R. V., & Daly, M. C. (2020). Employment discrimination law and economics. Journal of Economic Perspectives, 34(4), 123-142.
- EEOC (Equal Employment Opportunity Commission). (2020). Enforcement Guidance on Retaliation and Related Issues. Washington, D.C.
- Griggs v. Duke Power Co., 401 U.S. 424 (1971).
- Kolstad v. American Dental Ass’n, 527 U.S. 526 (1999).
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973).
- McKennon v. Nashville Banner Publishing Co., 513 U.S. 352 (1995).
- Reeves v. Sanderson Plumbing Products, Inc., 530 U.S. 133 (2000).
- Vance v. Ball State University, 570 U.S. 421 (2013).
- Faragher v. Boca Raton, 524 U.S. 775 (1998).
- Faragher v. City of Boca Raton, 524 U.S. 775 (1998).