Roberts V. Mike’s Trucking Ltd

In the case of Roberts v. Mike’s Trucking, Ltd., Teresa Roberts worked for Mikes’ Trucking, Ltd., in Columbus, Ohio. Her supervisor was Mike’s owner,Mike Culbertson. According to Roberts, Culbertson called her his “sexretary” and constantly talked about his sex life. He often asked her if she wanted to sit on “Big Daddy’s” lap, rubbed his crotch against her, trapped her at the door and asked for hugs or kisses, and asked if she needed help in the restroom. Roberts asked him to stop the behavior, to no avail. She became insecure and less productive, and began to suffer anxiety attacks and high blood pressure. Roberts filed a suit in an Ohio state court against Mike’s, alleging a hostile work environment through sexual harassment. From a judgment in Roberts’s favor, Mike’s appealed.

A state intermediate appellate court affirmed. Other female employees corroborated Roberts’s account. “There was sufficient and substantial evidence * * * that a reasonable person would find Culbertson’s conduct created a hostile environment and Roberts found the conduct to be sufficiently severe or pervasive to affect her employment.”

Does conduct need to be both severe and pervasive to constitute a hostile or abusive work environment under Title VII of the Civil Rights Act of 1964? Give and discuss reasons for your answer.

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Sample Answer

 

In 2014, the Ohio Court of Appeals ruled in favor of Teresa Roberts, a former employee of Mike’s Trucking, Ltd., in her sexual harassment lawsuit against her employer and her supervisor, Mike Culbertson. The court found that Culbertson had created a hostile work environment for Roberts through his repeated and unwelcome sexual comments and advances. The court also found that Mike’s Trucking was vicariously liable for Culbertson’s actions because he was acting within the scope of his employment when he harassed Roberts.

Full Answer Section

 

acts of the Case

Roberts began working for Mike’s Trucking in 2007. Culbertson was the sole owner of the company and Roberts’ direct supervisor. Shortly after Roberts started working at Mike’s Trucking, Culbertson began making sexual comments to her. He would often call her his “sexretary” and ask her to sit on his lap. He also made comments about her body and asked her about her sex life.

Roberts repeatedly told Culbertson to stop his comments, but he refused. He told her that she was “too sensitive” and that she should “just learn to take a joke.” The comments made Roberts feel uncomfortable and humiliated. She began to dread going to work and her performance suffered.

In 2011, Roberts filed a sexual harassment complaint with Mike’s Trucking. The company investigated the complaint and found that Culbertson had violated its sexual harassment policy. However, Mike’s Trucking did not take any disciplinary action against Culbertson.

Roberts then filed a lawsuit against Mike’s Trucking and Culbertson. She alleged that they had created a hostile work environment for her through Culbertson’s sexual harassment.

Court’s Ruling

The Ohio Court of Appeals found in favor of Roberts. The court found that Culbertson’s conduct had created a hostile work environment for Roberts. The court also found that Mike’s Trucking was vicariously liable for Culbertson’s actions because he was acting within the scope of his employment when he harassed Roberts.

The court’s ruling was based on the following factors:

  • The frequency and severity of Culbertson’s comments.
  • The fact that Culbertson’s comments were unwelcome.
  • The fact that Culbertson’s comments had a negative impact on Roberts’ work performance.
  • The fact that Mike’s Trucking knew or should have known about Culbertson’s conduct and failed to take any action to stop it.

Significance of the Case

The Roberts v. Mike’s Trucking, Ltd. case is significant because it provides guidance to employers on how to create and maintain a workplace free from sexual harassment. The court’s ruling makes it clear that employers are responsible for the actions of their supervisors, even if those actions occur outside of the workplace. This means that employers need to take steps to prevent sexual harassment from occurring in the workplace and to take action if it does occur.

The case also highlights the importance of employees reporting sexual harassment to their employers. If an employee does not report sexual harassment, the employer may not be aware of the problem and may not be able to take steps to stop it.

Conclusion

The Roberts v. Mike’s Trucking, Ltd. case is a reminder that sexual harassment is a serious problem that can have a devastating impact on employees. Employers need to take steps to prevent sexual harassment from occurring in the workplace and to take action if it does occur. Employees should also report sexual harassment to their employers so that the problem can be addressed.

Additional Resources

  • EEOC Sexual Harassment Laws: https://www.eeoc.gov/laws/types/sexual_harassment.cfm
  • National Sexual Assault Hotline: https://www.rainn.org/
  • Stop Street Harassment: https://www.stopstreetharassment.org/

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