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Legislative Process Keyed to Mikva, 5th Ed.
Landgraf v. USI Film Products
Citation:
511 U.S. 244, 114 S.Ct. 1483, 128 L.Ed.2d 229 (1994)Facts
From September 1984 to January 1986, Barbara Landgraf worked the night shift at USI Film Products in Tyler, Texas. During her employment, she was repeatedly sexually harassed by a male coworker named John Williams, who made inappropriate remarks and had physical contact with her. After her complaints to her immediate supervisor brought no relief, she reported the incidents to the personnel manager, who investigated, reprimanded Williams, and transferred him to another department. Four days later, Landgraf quit her job. The EEOC determined that Landgraf had likely been the victim of sexual harassment creating a hostile work environment but concluded that her employer had adequately remedied the violation. In July 1989, Landgraf filed suit. The District Court found that Williams had sexually harassed Landgraf but that she had not been constructively discharged and thus was not entitled to relief under then-existing Title VII law. While her appeal was pending, on November 21, 1991, the Civil Rights Act of 1991 was enacted, which created new remedies including compensatory and punitive damages for intentional discrimination and provided for jury trials in such cases.
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