Case details

Plaintiffs claimed sexual discrimation at workplace

SUMMARY

$0

Amount

Verdict-Defendant

Result type

Not present

Ruling
KEYWORDS
emotional distress, mental, psychological
FACTS
In 2007, plaintiffs Yvette Daniels, Maria Aguilar and Karen Currie, all employees of the State of California Department of Corrections and Rehabilitation, were allegedly subjected to sexually explicit materials in the workplace. Daniels, a youth counselor for the Department of Corrections, also alleged that her supervisor, Mark Miranda, retaliated against her for complaining about youth offenders improperly possessing the explicit materials. Daniels, Aguilar and Currie, individually and on behalf of all persons similarly situated, sued the State of California Department of Corrections and Rehabilitation, alleging that its actions constituted sexual discrimination. Daniels also commenced a separate lawsuit against Mark Miranda, alleging that Miranda’s actions constituted retaliation. The matters would have been joined for trial, but Daniels’ retaliation suit was dismissed on a motion to strike. In addition, plaintiffs Aguilar and Currie were dismissed from the case after defense counsel was granted summary judgment against them. Thus, the matter only proceeded to trial with Daniels’ claim against the Department of Corrections regarding the alleged sexual discrimination. Daniels stated that she confiscated magazines, such as “Smooth,” “Maxim,” “King,” and “Black Men,” which she believed to be sexually explicit and/or sexually oriented and were in violation of the Department of Correction’s regulations and policies. She also stated she confiscated video games that allegedly depicting sexual content, violence, and mature content. However, Daniels claimed that she was told that Miranda had approved those materials and even brought in movies with offensive material, such as “American History X,” which depicts a rape of an inmate, and “300,” which depicts rape, female nudity, and orgies. Thus, Daniels claimed that the Department of Corrections was lax on the enforcement of its policies regarding public display of sexually explicit material by youth offenders and that this put her and other female employees in danger by making them a target for hostile and aggressive inmates. Counsel for the Department of Corrections argued that Daniels was neither discriminated nor retaliated against. Counsel contended that the Department of Corrections’ policy was that sexually oriented material differs from sexually explicit material, as it can be possessed, but not openly displayed by wards. Counsel also contended that the policy further stated that correctional officers have the authority to confiscate any sexually oriented material that are openly displayed by wards and subject the wards to discipline. Thus, the Department of Corrections’ counsel argued that the Department had policies and procedures addressing sexual materials (explicit or otherwise), that the Department supported Daniels’ complaints regarding sexual materials, and that Daniels’ exposure to sexual materials in the workplace was not severe and pervasive that it altered the terms and condition of her employment with the Department., Daniels claimed that she suffered emotional distress as a result of the sexual discrimination against her. Thus, she sought recovery of damages for emotional pain and suffering.
COURT
United States District Court, Eastern District, Sacramento, CA

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