EEOC v. CRST Van Expedited, Inc.
The EEOC filed suit against CRST, one of the country's largest interstate trucking companies, alleging that CRST subjected Monika Starke "and approximately 270 similarly situated female employees" to a hostile work environment, in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq. The EEOC alleged that CRST was responsible for severe and pervasive sexual harassment in its New-Driver Training program. The court reversed the district court's grant of summary judgment on the EEOC's claims as to Starke because the EEOC, suing as plaintiff in its own name under section 706 of Title VII, could not be judicially estopped because of Starke's independent conduct; reversed the district court's grant of summary judgment on the EEOC's claims on behalf of Tillie Jones because the EEOC had produced sufficient evidence to create a genuine fact issue as to the severity or pervasiveness of harassment that she allegedly suffered; vacated, without prejudice, the district court's award of attorneys' fees to CRST because CRST was no longer a "prevailing" defendant under 42 U.S.C. 2000e-5(k); and affirmed the remainder of the district court's orders and remanded for further proceedings.