- Employment Discrimination

Markie Mann is a partner at Mann, Mann & Mann ("MMM"), a public accounting firm based in Seattle, WA. Markie, along with her two sisters, are the sole owners of MMM. Markie is the direct supervisor of Millicent Mandrake, a junior accountant with MMM. Markie tells Millicent that retention and promotion depends on whether she is seen as a "team player" who is "loyal" and "subordinate." Markie regularly criticizes Millicent for failing to "maintain proper social decorum". Markie dislikes Millicent's "casual" clothing. Markie regularly criticizes Millicent for failing to act "like a proper lady". On several occasions, Markie handed Millicent pictures of women wearing the type of clothing Markie deemed proper. "That" said Markie "is how a woman ought to dress in the office".

Each Friday, for the past several months, Markie has taken Millicent to dinner at a local club. The conversations have always been professional, but Millicent feels uncomfortable due to the amount of "touching" that happens during dinner (e.g., Markie's hand lingers on Millicent's each time documents are passed from one person to the next, at the end of dinner Markie gives Millicent a brief hug, and on at least three occasions Markie gave Millicent a quick kiss on the cheek exclaiming "Just like they do in France!".). In addition, at least once per week, Markie slaps Millicent on the back and says "We ought to go out for a movie. I bet we'd have a lot of fun together!" Millicent politely rejects Markie's invitations.

Millicent "quietly" identifies as a lesbian (though, at times, Millicent considers her gender identity as "fluid"). Markie has never discussed her sexual identity with anyone from MMM. At the end of Millicent's first year with MMM, Markie dismisses Millicent for "failing to maintain proper decorum". Millicent sues Markie and MMM. In her lawsuit, Millicent claims sexual identity discrimination and hostile workplace discrimination in violation of Title VII and RCW 49.60.30. Answer the following questions:

1. Does Millicent have a valid claim based on Title VII?

2. Does Millicent have a valid claim pursuant to RCW 49.60.030

Explain, in detail, the arguments each party can make.