Burlington Industries, Inc. v. Ellerth

Kimberly Ellerth (plaintiff) worked for Burlington Industries (defendant), where mid-level manager Ted Slowik, who was above her direct supervisor, repeatedly made sexist and sexually demeaning comments and remarks she interpreted as threats against her advancement, even after she received a promotion. Ellerth never reported Slowik's conduct during her employment, resigned for other stated reasons, but later told Burlington in a letter that Slowik's behavior was the real reason she left, then sued under Title VII claiming Burlington was vicariously liable; the district court granted Burlington summary judgment, finding no negligence despite a hostile environment, and the court of appeals reversed.