Oncale v. Sundowner Service Inc.
523 U.S. 75, 118 S.Ct. 998, 140 L.Ed.2d 201 (1998)

  • Oncale was working on an oil platform. He claimed that he was sexually assaulted by some of the other workers on the oil platform.
  • Oncale complained to his company, Sundowner, but they took no actions. He sued under Title VII of the Civil Rights Act for discrimination related to sexual harassment.
  • The Trial Court found for Sundowner in summary judgment. Oncale appealed.
    • The Trial Court found that "Mr. Oncale, a male, has no cause of action under Title VII for harassment by male co-workers."
  • The Appellate Court affirmed. Oncale appealed.
  • The US Supreme Court reversed.
    • The US Supreme Court looked to the plain language of Title VII and found that it prohibits discrimination "because of sex." That implies that it protects men as well as women.
      • The Court noted that they have previously held that Title VII covers people discriminating against members of their own race, so it should cover people discriminating against members of their own sex.
    • The Court noted that Congress probably never considered that this Statute would be applied in male on male harassment cases, but that isn't important, as long as the plain language of the text is clear.
      • See Church of the Holy Trinity v. United States (143 U.S. 457 (1892), which came to pretty much the opposite conclusion. In that case, the Court said that purpose trumps plain language.
    • The Court suggested that courts should judge individual cases from the perspective of a reasonable person, and what might not be considered sexual harassment in one situation could be sexual harassment in another.