Meyer v. Post Road Auto Body Shop
To prove "quid pro quo" sexual harassment, a plaintiff employee must prove she received favorable treatment in return for sexual favors. In February 2008, the defendant, Post Road Auto Body Shop, hired the plaintiff, Nancy Meyer, as an office assistant. Between May and September 2009, Meyer resided in the home of the defendant's president, Joseph Castellana. In or about December 2009 or January 2010, Meyer argued with Castellana and complained that he was engaging in sexual relationships with other women. Soon afterward, Castellana discharged her. Meyer sued Post Road Auto Body Shop, alleging "quid pro quo" sexual harassment, in violation of Connecticut General Statutes §46a-60(a)(8), because her romantic relationship with the boss allegedly was a requirement of her continued employment. The court found that Meyer did not prove that she was discharged because the sexual relationship ended. There was evidence that neither party committed to a sexually exclusive relationship. In March 2010, Meyer sent an e-mail to thank Castellana for his attention and to apologize if she harmed him. "[T]he plaintiff's e-mail of March 1, 2010," wrote the court, "renders unacceptable her assertion that the unilateral discontinuance of the sexual relationship by the employer caused the termination of her employment." Meyer admitted that she could have continued to work for Castellana, if she had kept her personal and business lives separate. Castellana denied that the employment relationship ended because the sexual relationship ended. The court credited Castellana's version of events. Meyer did not prove that sexual relations were an express or implied condition of continued employment. Meyer did not prove her claim of "quid pro quo" sexual harassment, wrote the court, because "[s]ex was not implicit in the employment relationship, it was coincidental." The court granted judgment to the defendant employer.