Seyfarth Synopsis: The Eighth
Circuit Court of Appeals ruled that a manager's behavior toward
an employee was "reprehensible and improper," but did not
rise to the level of a hostile work environment under Title VII,
and affirmed summary judgment for defendants.
In
Paskert v. Kemna-ASA Auto Plaza, Inc., et al., a
former sales associate brought suit against Auto Smart alleging
hostile work environment sexual harassment in violation of Title
VII. The U.S. District Court for the Northern District of Iowa
granted Auto Smart's motion for summary judgment, and plaintiff
appealed the decision to the Eighth Circuit Court of Appeals.
The summary judgment record reflected that plaintiff's
supervisor's conduct was volatile, and that his "treatment
toward women was demeaning, sexually suggestive, and
improper." The supervisor bragged about his purported sexual
conquests, and on one occasion, he attempted to rub plaintiff's
shoulders and said he was going to give her a hug.
