Bundy v. Jackson
United States Court of Appeals for the District of Columbia Circuit
641 F.2d 934 (D.C. Cir. 1981)
Sandra Bundy (plaintiff), a vocational-rehabilitation specialist at a D.C. government agency, sued her supervisor Delbert Jackson (defendant) for pervasive sexual harassment, including repeated propositions from multiple supervisors and a superior who told her any man would want to rape her; when she rejected the advances, a supervisor began criticizing her performance without prior complaint, though the district court found sexual harassment was simply a normalized condition of employment at the agency, affecting other employees too. Despite these findings, the district court denied Bundy any relief because her specific rejection of the advances hadn't triggered any adverse employment action against her, and Bundy appealed.
Whether a plaintiff may obtain injunctive relief for a sexually hostile work environment under Title VII even when her resistance to the harassment did not result in employer retaliation against her.