Pennsylvania State Police v. Suders
Headline: Court allows employers to use anti‑harassment policy defense in many constructive‑discharge claims but bars that defense when a supervisor’s official act forces an employee to resign, shaping workplace harassment suits.
Holding: The Court held employers can assert the Ellerth/Faragher affirmative defense against hostile‑environment constructive‑discharge claims unless the employee quit in reasonable response to a supervisor’s official act that changed her employment status.
- Permits employers to use anti‑harassment policy defense when no official act forced resignation.
- Bars that defense when a supervisor’s official act (demotion, pay cut, transfer) causes quitting.
- Remands Suders' claim for trial because factual disputes about harassment and policies remain.
Summary
Background
Nancy Drew Suders was a police communications operator who says three supervisors at her state police barracks subjected her to repeated, severe sexualized conduct and insults — including obscene gestures, vulgar comments, and intimidation. She told the Equal Employment Opportunity officer she was afraid; two days later her supervisors arrested her on a staged theft allegation, and she resigned soon after. Suders sued the Pennsylvania State Police under Title VII, alleging a hostile work environment and that the harassment forced her to quit (constructive discharge).
Reasoning
The Court examined whether a constructive discharge caused by supervisor harassment should automatically count as a
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