Corrales v. Chase Bankcard Service, Inc.
Docket: No. 04-15355
Court: Court of Appeals for the Ninth Circuit; April 11, 2005; Federal Appellate Court
Joyce A. Corrales appeals the district court's dismissal of her claim against Chase Bankcard Services for a hostile work environment and constructive discharge under Title VII of the Civil Rights Act of 1964. The appeal is reviewed de novo by the court, which has jurisdiction under 28 U.S.C. 1291. The district court dismissed Corrales' constructive discharge claim, finding she only alleged a single incident of sexual harassment without sufficient aggravating factors. However, the appellate court determined that Corrales presented a pattern of aggravating factors, including inappropriate questioning about her sex life by a male diversity officer and her subsequent complaints to supervisors, which were dismissed. The court noted that the Equal Employment Opportunity Commission found the bank's harassment policy to violate Title VII. The appellate court ruled that the district court erred in dismissing both the constructive discharge and hostile work environment claims, emphasizing that a reasonable woman in Corrales' position would find her employment conditions altered by the diversity officer's actions. The court did not address Corrales' potential quid pro quo claim since it was not raised at the district level. The case is reversed and remanded for further proceedings. This decision is not for publication and cannot be cited except as allowed by Ninth Circuit Rule 36-3.