Williamson V Houston Case Study

Williamson v. The City of Houston, Texas, 148 F.3d 462 (1998)
Facts:
Linda W illiamson was a police officer with the Houston Police Department. After 6 years with the department, she was assigned to the Organized Crime Squad. She was partnered with a male officer, Doug McLeod, they often rode in the same vehicle, and their desks were close to each other. McLeod continually sexually harassed W illiamson for nearly two years. McLeod would make comments about Williamson’s appearance and touch her in an unwanted manner. Williamson told McLeod to stop several times and notified their immediate supervisor. About 18 months in Williamson told their supervisor Sergeant Bozeman that she was tired of the sexual harassment and wanted a transfer out of

Court Deciding:
United States Court of Appeals, Fifth Circuit
Decision:
The United States District Court Southern District of Texas ruling was affirmed granting the judgment to Williamson.
Principle of Law:
When an organizations policy defines the process for filing a sexual harassment complaint and the employee follows the process the organization will be liable even if a supervisor does not follow the policy.
Notes and Comments:
Joanna L. Grossman wrote an article entitled The First Bite is Free: Employer Liability for Sexual Harassment, in this article she talks about the old common law where a dog’s owner would not be held liable for the first bite of their dog. The first bite, however, was counted a notice and any subsequent bite would hold liability. The same logic has been applied to work place harassment (Grossman, 2000). If it occurs, the organization has one chance to fix the problem after being notified. This case argued the notification aspect to attempt to vacate the judgment. The court found that an employee