Sexual Harassment in the Workplace
by
Joseph C. Maya on Jan. 22, 2024
Summary: What may or may not constitute sexual harassment in the workplace can be a tricky subject. The Connecticut Superior Court ruled on a specific provision of Connecticut’s sexual harassment law, specifically, the provision defining sexual harassment as “any conduct of a sexual nature” when “submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment.”
In Meyer v. Post Road Auto Body Shop, plaintiff Meyer sued her former employer, defendant Post Road Auto Body Shop (“Post Road”), and its owner, Joseph Castellana. She alleged that her employment was terminated in violation of Connecticut General Statute 46a-60(a)(8), which defines sexual harassment.[1]
Case Details
The facts of the case are as follows. Meyer was employed by Post Road for two years, and had been in a sexual relationship with Castellana prior to being hired and during her employment.[2] When Meyer learned that Castellana was dating other women, she ended their relationship. According to the complaint, she was immediately terminated from her position as office assistant.[3]
In her complaint, Meyer alleged that her termination not only violated Connecticut’s sexual harassment law, but that it violated Title VI of the Civil Rights Act of 1964, among other claims. Ruling on the defendants’ motion for summary judgment, which alleged that there were no genuine issues of material fact, the court agreed with the plaintiff, finding that “the evidence shows that there is a material issue of fact as to whether the plaintiff’s continuation of her sexual relationship with Castellana was either explicitly or implicitly a term or condition of her continued employment with Post Road.”[4]
The Court’s Decision
With that, the Court rejected the defendant’s argument that the plaintiff was not terminated because she refused Castellana’s sexual advances. Essentially, the court found that the defendant’s reasoning and understanding of Connecticut’s statute relating to sexual harassment was shortsighted, and didn’t address the argument that Meyer’s employment hinged on her continuation of their sexual relationship.
[1] Meyer v. Post Road Auto Body Shop, 2012 Conn. Super. LEXIS 803 (Mar. 27, 2012).
[2] Id. at 1.
[3] Id.
[4] Id. at 6.
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