Sexual Harassment Lawsuit Filed Against Warren County Sheriffs Department
A sexual harassment and discriminatory promotion lawsuit alleging $15 million in damages was filed against former Warren County Sheriff Larry Cleveland and the Warren County Sheriff’s Department by two veteran female correctional officers, Michelle LeBarron and Cynthia VanDenburgh. The complaint alleges they were discriminated against due to their sex and that they were subjected to sexual discrimination, sexual harassment and inappropriate conduct by Sheriff Cleveland and the county.
The lawsuit was filed in U.S. District Court in Albany last May after first filing a complaint under Title VII of the Civil Rights Act of 1964 with the Equal Employment Opportunity Commission. Title VII prohibits employment discrimination based on race, color, religion, sex and national origin. Title VII applies to employers with 15 or more employees, including federal, state, and local governments. Title VII also applies to private and public colleges and universities, employment agencies, and labor organizations.
Here are United States Supreme Court cases that provide more information about Title VII.
Griggs v. Duke Power Co., 401 U.S. 424 (1971)
In a race discrimination case, the Supreme Court used “disparate impact” theory to analyze employment discrimination under Title VII.
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973)
The Supreme Court gave the framework for proving disparate treatment discrimination. The four-part test, also known as the McDonnell Douglas test, requires that a plaintiff establish a prima facie case by showing she (1) belongs to a protected class, (2) is qualified for the position, (3) suffered an adverse employment action, and (4) was replaced with someone outside the protected class.
Texas Department of Community Affairs v. Burdine, 450 U.S. 248 (1981)
The Supreme Court held that the defendant must produce a legitimate, nondiscriminatory explanation for its decision in firing but they do not have to persuade the court that it was actually motivated by this reason. This case is seen as a win for the employer and makes it more difficult for employees to sue under Title VII.
Meritor Savings Bank v. Vinson, 477 U.S. 57 (1986)
The Supreme Court held that employees could establish Title VII civil rights violations by showing that discrimination based on sex created a hostile work environment.
Clark County School District v. Breeden, 533 U.S. 912 (2001)
The Supreme Court held that conduct must be severe and pervasive and that a single remark does not constitute sexual harassment under Title VII.
