Sanders v. Lanier

The plaintiff worked as a youth services officer with the Dyer County Juvenile Court, where she alleged that a Chancery Court judge sexually harassed her verbally and physically. When she rejected his advances, the judge demoted her from her supervisory position, denied her salary increases, and altered her job requirements weekly. She sued the judge for quid-pro-quo sexual harassment, in violation of the Tennessee Human Rights Act (“THRA”). The Dyer County Chancery Court determined that the State was not the plaintiff’s employer for purposes of the THRA and dismissed her complaint for failing to state a cause of action. The Court of Appeals of Tennessee reversed and the Supreme Court of Tennessee affirmed the Court of Appeals decision. The Supreme Court of Tennessee held that the plaintiff did state a cause of action because the State was the plaintiff’s employer and the defendant was a supervisor acting in the scope of his employment, making the employer strictly liable under an “alter-ego” theory of liability.



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