Oncale v. Sundowner Service Inc. case brief

Oncale v. Sundowner Service Inc. case brief summary
523 U.S. 75, 118 S.Ct. 998, 140 L.Ed.2d 201 (1998)

CASE SYNOPSIS: Petitioner employee sought review of a judgment of the United States Court of Appeals for the Fifth Circuit, which held that he had not been discriminated against because his harasser was of the same sex in the employee's suit against respondent employer. The case presented the question of whether workplace harassment violated Title VII's prohibition against discrimination because of sex under 42 U.S.C.S. § 2000e-2(a)(1).

CASE FACTS: On several occasions, the employee was forcibly subjected to sex-related, humiliating actions against him by fellow employees in the presence of the rest of the oil-platform crew. He was also physically assaulted in a sexual manner and was threatened with rape. When his complaints to supervisory personnel produced no remedial action, the employee filed a complaint against his employer, alleging that he was discriminated against in his employment because of his sex. The district court granted the employer's motion for summary judgment, which the appellate court affirmed, holding that the employee, who was a male, had no cause of action under Title VII for harassment by male co-workers.

DISCUSSION

• On certiorari, the Court held that nothing in Title VII necessarily barred a claim of discrimination because of sex merely because the plaintiff and the defendant, or the person charged with acting on behalf of the defendant, were of the same sex. 
• In reversing the judgment, the Court concluded that sex discrimination consisting of same-sex sexual harassment is actionable under Title VII.

CONCLUSION: The Court reversed the appellate court's order and remanded the case for further proceedings.