Jones v. Clinton
990 F.Supp. 657 (1998)
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Rule of Law:
A single, non-violent incident of unwelcome sexual conduct is not sufficiently severe or pervasive to constitute actionable hostile work environment harassment under § 1983. Additionally, a claim for quid pro quo harassment fails without evidence of a tangible job detriment resulting from the rejection of sexual advances.
Facts:
- On May 8, 1991, Paula Corbin Jones was an employee of the Arkansas Industrial Development Commission (AIDC) working at a conference at the Excelsior Hotel in Little Rock.
- At the conference, Arkansas State Police Officer Danny Ferguson, who was part of then-Governor William Jefferson Clinton's security detail, invited Jones to meet the Governor in a hotel suite.
- Inside the suite, Clinton allegedly made unwelcome sexual advances, which included touching Jones's leg, attempting to kiss her neck, and lowering his trousers to expose his penis and ask her to 'kiss it.'
- Jones rejected the advances, stated she was 'not that kind of girl,' and left the suite.
- As she was leaving, Clinton allegedly told her, 'You are smart. Let’s keep this between ourselves.'
- Jones continued to work at the AIDC for 19 months following the incident, during which she received all merit and cost-of-living pay increases for which she was eligible.
- Jones alleged her supervisors treated her rudely and her job duties were changed after returning from maternity leave, but she suffered no demotion, loss of pay, or loss of benefits.
- Jones voluntarily left her job at the AIDC in February 1993 to move to California with her husband.
Procedural Posture:
- Paula Corbin Jones filed a lawsuit against William Jefferson Clinton and Danny Ferguson in the U.S. District Court for the Eastern District of Arkansas.
- The case was appealed to the U.S. Supreme Court on the preliminary issue of presidential immunity from civil litigation.
- The Supreme Court held that the lawsuit could proceed against a sitting President for actions taken before his term of office began and remanded the case to the district court.
- On remand, Clinton filed a motion for judgment on the pleadings, which the district court granted in part, dismissing Jones's defamation and certain due process claims.
- Jones was granted leave to file an amended complaint, after which Clinton and Ferguson filed motions for summary judgment on all remaining claims.
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Issue:
Does a single alleged incident of unwelcome sexual advances by a supervisor, which was rejected and did not result in any tangible job detriment to the employee, constitute actionable quid pro quo or hostile work environment sexual harassment under 42 U.S.C. § 1983 or intentional infliction of emotional distress under state law?
Opinions:
Majority - Wright, District Judge
No, this single incident does not constitute actionable sexual harassment or intentional infliction of emotional distress. To establish quid pro quo sexual harassment, a plaintiff must demonstrate that rejecting a supervisor's advances resulted in a tangible job detriment, which Paula Jones failed to do. To establish hostile work environment harassment, the conduct must be so severe or pervasive as to alter the conditions of employment, and this single, boorish incident, while offensive, does not meet that high standard. Finally, Jones's claim for intentional infliction of emotional distress fails because the alleged conduct was not 'extreme and outrageous' under Arkansas's rigorous standard, and she failed to show she suffered emotional distress so severe that no reasonable person could endure it. The court analyzed each of Jones's claims and found them insufficient to survive summary judgment. For the quid pro quo claim, the court found no evidence of tangible job detriment; Jones received regular pay raises and satisfactory performance reviews, and her complaints about changed job duties did not constitute a 'materially significant disadvantage.' For the hostile work environment claim, the court determined that the hotel incident, combined with a few other minor encounters, was not frequent, severe, or physically threatening enough to create an abusive working environment. Because both federal sexual harassment claims failed, the § 1985 conspiracy claim also failed for lack of an underlying constitutional violation. Finally, applying the strict standards of Arkansas law for the tort of outrage, the court concluded that the conduct, while offensive, did not rise to the level of 'atrocious and utterly intolerable in a civilized community,' and Jones's own actions after the incident did not demonstrate the requisite level of severe emotional distress.
Analysis:
This case set a significant, though non-binding, precedent at the district court level clarifying the high threshold for sexual harassment claims. The court's decision distinguished between behavior that is merely 'boorish and offensive' and conduct that is legally actionable as 'severe or pervasive' under Title VII and § 1983 standards. It reinforced the necessity for plaintiffs in quid pro quo cases to prove a concrete, 'tangible job detriment,' making it more difficult to bring claims based on unfulfilled threats or perceived slights. The ruling was influential in shaping the legal and public understanding of what constitutes a hostile work environment, suggesting that isolated incidents, unless extremely serious (like a physical assault), are insufficient to alter the conditions of employment.
