Jones v. Clinton
990 F. Supp. 657 · District Court, E.D. Arkansas · 1998
Facts
Paula Corbin Jones sued President Bill Clinton and Danny Ferguson, a state trooper, alleging sexual harassment and other claims stemming from an incident in a hotel suite in 1991 when Clinton was Governor of Arkansas. Jones claimed Clinton made unwelcome sexual advances, and after she resisted, she suffered job detriments and emotional distress. The defendants moved for summary judgment on Jones's claims of quid pro quo sexual harassment, hostile work environment sexual harassment, conspiracy to violate civil rights, and intentional infliction of emotional distress.
Issue
Did Paula Jones present sufficient evidence to establish genuine issues of material fact for her claims of quid pro quo sexual harassment, hostile work environment sexual harassment, conspiracy to violate civil rights, and intentional infliction of emotional distress, thereby precluding summary judgment for the defendants?
Holding
The Court granted summary judgment for the defendants on all claims. It found that Jones failed to demonstrate any tangible job detriment for her quid pro quo claim and failed to show sufficiently severe or pervasive conduct for her hostile work environment claim, leading to the dismissal of her conspiracy claim as well. The Court also held that the alleged conduct, while offensive, did not meet the rigorous standards for intentional infliction of emotional distress under Arkansas law.
Rule
To establish quid pro quo sexual harassment under § 1983 (analyzed under Title VII standards), a plaintiff must show a tangible job detriment resulting from the refusal of unwelcome sexual advances. Hostile work environment sexual harassment requires conduct sufficiently severe or pervasive to alter employment conditions and create an abusive environment. A § 1985(3) conspiracy claim requires an underlying violation of federal law, and intentional infliction of emotional distress in Arkansas demands conduct so extreme and outrageous as to be utterly intolerable in a civilized community, causing distress so severe that no reasonable person could endure it.
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