Downtown Lawyer

After working as a sales representative for three years at C.H. Robinson Worldwide, Ingrid Reeves sued the company for allegedly subjecting her to a hostile work environment in violation of Title VII. Reeves alleged she was subjected daily to gender-specific vulgarities (“bitch,” “fucking bitch,” “fucking whore,” “crack whore,” and “cunt”) from her male co-workers. She stated they also talked within ear-shot about masturbation and bestiality and often listened to a Howard Stern-like radio show loaded with sexual references. The trial court dismissed Reeves’s claims. The trial court found that the language and sexual comments were not directed at her specifically. Because the offensive behavior was not motivated by her gender, the trial court held that Reeves had no Title VII claims.

On appeal, the Eleventh Circuit Court of Appeals initially reversed the trial court’s ruling, holding that Reeves had presented a jury question about whether the offensive conduct was based on her sex. In 2009, the court vacated that ruling and agreed to rehear the case en banc. In a unanimous ruling, the court held that a jury could reasonably find that the offensive conduct was “humiliating and degrading” to women specifically, stating as follows:

Instead, a jury reasonably could find that it was a workplace that exposed Reeves to disadvantageous terms or conditions of employment to which members of the other sex were not exposed. Title VII was plainly designed to protect members of a protected group from adverse conditions of employment like those Reeves alleges were endemic to C.H. Robinson.

The court further noted that referring to a female as a “bitch” is “firmly rooted in gender” and that such language “is humiliating and degrading based on sex” regardless of the intended target.

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