Pennsylvania State Police v. Suders

Summary

The Supreme Court addressed employer liability under Title VII for a hostile-work-environment constructive discharge caused by supervisor sexual harassment. It held that the Ellerth/Faragher affirmative defense is unavailable when a supervisor's official act precipitates the constructive discharge, but remains available when the discharge results solely from unofficial supervisory conduct. The Court vacated the Third Circuit's judgment and remanded the case for further proceedings.