Sandra Shope had worked as chief of county housing services in Loudoun County, Virginia, for some six

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Sandra Shope had worked as chief of county housing services in Loudoun County, Virginia, for some six years when Timothy Krawczel was made her boss. Shope testified that Krawczel pounded his fists on her desk and called her a " stupid woman" in front of coworkers and berated her as "weak like a woman." Krawczel told Shope, "I'm the boss at home, and I will be the boss here." Shope testified that Krawczel never touched her or sought sexual favors. Krawczel was not abusive to men in the office, but the evidence suggested that other women in the office were subjected to "insults." The county defended that Krawczel was strict with Shope because she was not doing her job well. Shope responded that she worked more than 50 hours per week and was a respected housing official. Shope sought relief from the all-male County Board of Supervisors, but her complaints were ignored. She became physically ill as a result of the treatment by Krawczel and ultimately resigned.
Shope contends that the county and Krawczel constructively discharged her in violation of Title VII. She seeks back pay, compensatory damages for the pain and suffering involved, and punitive damages from Krawczel.
Can the county and Krawczel be guilty of sexual harassment when no sexual favors were sought and no sexual conduct was involved? Is the fact that Krawczel was not abusive to any male employees of any legal significance? Could the county be required to pay punitive damages? Decide. [Shope v. Loudoun County, Washington Post, col. 3, p. 1, June 20, 1992]

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