Muzzy v. Cahillane Motors, 434 Mass. 409 (2001)

An employee alleged that her female supervisor subjected her to a sexually hostile environment under G.L. c. 151B, § 4(16A), claiming unwelcome physical and verbal sexual conduct that interfered with her work. The supervisor denied the allegations, asserting that any romantic or physical interactions were consensual. After a jury found for the supervisor, the employee appealed, arguing that the trial judge’s jury instruction to apply the standard of an “objectively reasonable woman of lesbian orientation” was erroneous and prejudicial. The Supreme Judicial Court held that the employee had waived most objections by agreeing to the instruction during trial and failing to object until after closing arguments. The Court did clarify that future jury instructions should use the general “reasonable person in the plaintiff’s position, considering all the circumstances” standard from Oncale v. Sundowner Offshore Services, Inc. It emphasized that adding specific characteristics (such as sexual orientation) risks confusion and prejudice. Finding no reversible error or prejudice, the Court affirmed the judgment for the employer.

Topics

• Employment discrimination
• LGBTIQ

Geographical location

• North America
• United States
• Massachusetts

Keywords

• hostile work environment
• jury instructions
• reasonable person

Year

• 2001

External URL

• Muzzy v. Cahillane Motors, 434 Mass. 409 (2001)

Court

• Supreme Judicial Court of Massachusetts

Type

• Domestic Case Law

Jurisdiction

• Massachusetts