Landgraf v. Usi Film Products

511 U.S. 244 (1994)

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Nature of the Case

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Facts

P was employed at USI (D). She worked the 11 p.m. to 7 a.m. shift operating a machine that produced plastic bags. A fellow employee named John Williams repeatedly harassed her with inappropriate remarks and physical contact. Petitioner's complaints to her immediate supervisor brought her no relief, but when she reported the incidents to the personnel manager, he conducted an investigation, reprimanded Williams, and transferred him to another department. Four days later, P quit her job. P filed a timely charge with the Equal Employment Opportunity Commission (EEOC or Commission). The Commission determined that P had likely been the victim of sexual harassment, creating a hostile work environment in violation of Title VII of the Civil Rights Act of 1964. It concluded that her employer had adequately remedied the violation. Accordingly, the Commission dismissed the charge and issued a notice of right to sue. The District Court found that Williams had sexually harassed P, causing her to suffer mental anguish. However, the court concluded that she had not been constructively discharged. P was not entitled to equitable relief, and because Title VII did not then authorize any other form of relief, the court dismissed her complaint. On November 21, 1991, while P's appeal was pending, the President signed into law the Civil Rights Act of 1991. The Court of Appeals rejected P's argument that her case should be remanded for a jury trial on damages pursuant to the 1991 Act. The Act did not specify whether it would apply retroactively to conduct or litigation that commenced before its enactment. The Supreme Court eventually granted certiorari.