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lawsuitappealharassment
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Mattern v. Eastman Kodak Co., 104 F.3d 702, 72 Fair Empl.Prac.Cas. (BNA) 1441, 70 Empl. Prac. Dec. P 44,742, 65 USLW 2478

Facts

Jean Mattern, an employee of Eastman Kodak Company, filed a Title VII charge with the EEOC alleging sexual harassment by her coworkers. Following her complaint, she experienced hostility from fellow employees, including theft of her tools and a hostile work environment. Although Eastman took some remedial actions, Mattern ultimately resigned and filed a lawsuit claiming retaliation. A jury found in her favor on the retaliation claim but ruled against her on the sexual harassment claim.

Mattern filed a Title VII charge with the EEOC on March 11, 1993, claiming sexual harassment by members of her on-the-job training crew. She alleged that two senior mechanics, Godwin and Roberts, had sexually harassed her and created a hostile work environment.

Issue

Did the actions taken by Eastman Kodak Company constitute 'adverse employment actions' under Title VII, thereby supporting Mattern's retaliation claim?

Did the actions taken by Eastman Kodak Company constitute 'adverse employment actions' under Title VII, thereby supporting Mattern's retaliation claim?

Rule

Under Title VII, a retaliation claim requires proof of three elements: (1) the employee engaged in protected activity; (2) the employer took adverse employment action against the employee; and (3) a causal connection exists between the protected activity and the adverse employment action. Adverse employment actions are defined as ultimate employment decisions, such as hiring, firing, promoting, or compensating an employee.

Analysis

The court analyzed whether the alleged actions by Eastman constituted adverse employment actions. It concluded that the hostility from coworkers, the theft of tools, and the anxiety Mattern experienced did not meet the threshold of ultimate employment decisions. Furthermore, the court found that the actions taken by supervisors, such as reprimands and threats, also did not rise to the level of adverse employment actions as they lacked significant consequences.

Conclusion

The court reversed the lower court's judgment in favor of Mattern on the retaliation claim, concluding that the evidence did not support a finding of adverse employment actions under Title VII.

We REVERSE and RENDER.

Who won?

Eastman Kodak Company prevailed in the appeal, as the court found that the actions Mattern complained of did not constitute adverse employment actions under Title VII. The court emphasized that the standard for proving retaliation is high and requires clear evidence of ultimate employment decisions, which Mattern failed to provide.

Eastman Kodak Company prevailed in the appeal, as the court found that the actions Mattern complained of did not constitute adverse employment actions under Title VII.

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