Eleventh Circuit Revives Harassment Claims In Light of Employer’s Failure to Investigate

A pair of companies operating a chiropractic clinic in Mobile, Ala., did not meet their burden of showing that reasonable steps were taken to correct sexual harassment reported by the clinic’s receptionist, the U.S. Court of Appeals for the Eleventh Circuit held June 1 (Kurtts v. Chiropractic Strategies Grp. Inc., 11th Cir., 11-11546, 6/1/12).

Reversing a lower court’s grant of summary judgment to the employer on Crystal Kurtts’s claims under Title VII of the 1964 Civil Rights Act, the unanimous appeals panel observed that, when Kurtts first reported the actions of the clinic’s physician, Dr. Johnnie Morgan, ...