Ramsdell v. Western Mass. Bus Lines, Inc., 415 Mass. 673 (1993)

The plaintiff, a female employee, filed a complaint with the Massachusetts Commission Against Discrimination (MCAD) alleging sex discrimination, unequal pay, and denial of promotion by her employer. The Commission dismissed the complaint, and the plaintiff appealed. The Supreme Judicial Court affirmed the Commission’s decision. The Court reviewed the governing statutory framework under General Laws Chapter 151B Section 4(1) (1990), which prohibits employment discrimination on the basis of sex. Section 1(18) defines sexual harassment as sexual advances, requests for sexual favors, or other verbal or physical conduct of a sexual nature when submission to or rejection of such conduct is made a term or condition of employment or a basis for employment decisions, or when the conduct has the purpose or effect of unreasonably interfering with an individual’s work performance by creating an intimidating, hostile, humiliating, or sexually offensive work environment. Applying these standards, the Court concluded that the evidence presented did not support a finding of sexual harassment or sex discrimination within the meaning of Chapter 151B. The Court held that the Commission was entitled to dismiss the complaint because the alleged conduct did not rise to the level required to establish either quid pro quo harassment or a hostile work environment under the statute. The Commission’s factual determinations and application of the law were upheld.

Topics

• Employment discrimination
• Sexual harassment

Geographical location

• North America
• United States
• Massachusetts

Keywords

• harassment
• pay discrimination
• denial of promotion

Year

• 1993

External URL

• Ramsdell v. Western Mass. Bus Lines, Inc., 415 Mass. 673 (1993)

Court

• Supreme Judicial Court of Massachusetts

Type

• Domestic Case Law

Jurisdiction

• Massachusetts