Equal Employment Opportunity Commission vs. Skywest Airlines Inc.

Case Background

On August 17, 2022, Plaintiff  Equal Employment Opportunity Commission filed a workplace harassment lawsuit in the United States District Court, Texas Northern (Case number: 3:22cv1807). Senior Judge Sidney A Fitzwater presided over the case.

Cause

SkyWest Airlines employed Sarah Budd starting in January 2007, during which she held various roles before transferring to Dallas-Fort Worth as a Parts Clerk in August 2019. While working in the Parts and Maintenance Divisions, her coworkers and supervisors subjected her to severe workplace harassment. This included crude sexual comments, explicit remarks about her body, and inappropriate suggestions of sexual acts. A Maintenance Supervisor even suggested to her coworkers that she engage in prostitution during a parts pickup trip. Coworkers frequently made comments about rape and violent sexual acts in her presence.

On September 4, 2019, Budd reported the workplace harassment to her Parts Clerk Manager, who warned that taking action could make her more of a target. The ongoing hostile work environment forced her to take unpaid medical leave from October to December 2019. Upon her return, the harassment escalated, including sexually explicit behavior involving a candy jar, which caused her severe emotional distress.

Injuries

The persistent workplace harassment caused significant mental health impacts, requiring Budd to seek medical treatment. The hostile work environment disrupted her ability to perform her job duties and advance her career at SkyWest Airlines. She experienced severe emotional trauma, leading to crying episodes and workplace anxiety. After returning from leave, the company placed her on indefinite administrative leave without providing clear communication about her return, isolating her professionally and stalling her career advancement.

Damages

SkyWest Airlines’ failure to address workplace harassment caused Budd substantial financial and emotional harm. She lost wages and benefits due to her constructive discharge from employment and incurred medical expenses for mental health treatment. The Equal Employment Opportunity Commission (EEOC) sought extensive remedies, including permanent injunctive relief to prevent future workplace discrimination, back pay with interest, and compensatory damages for emotional distress. They also requested punitive damages for SkyWest’s malicious conduct and implementation of effective policies to protect employees’ rights. The unsafe work environment prompted demands for court-ordered compliance measures to prevent future workplace harassment.

Key Arguments and Proceedings

Legal representation

  • Plaintiff(s): Equal Employment Opportunity Commission (EEOC)
    • Counsel for Plaintiff: Alexa Rae Lang | Ann Henry | Brooke Elisa Lopez
  • Defendant(s): Skywest Airlines Inc.
    • Counsel for Defendants: Erin Elizabeth Drumm | Chad A Shultz

Claims

The EEOC filed claims under Title VII of the Civil Rights Act of 1964 and Title I of the Civil Rights Act of 1991. The lawsuit alleged that SkyWest Airlines created and maintained a hostile work environment based on sex, retaliated against Budd for reporting harassment, and constructively discharged her by failing to provide a clear return-to-work plan. Despite multiple complaints, SkyWest failed to take appropriate corrective action. The workplace harassment persisted, violating Budd’s equal employment opportunities.

Defense

SkyWest Airlines acknowledged Budd’s employment history and her position as a Parts Clerk in Dallas-Fort Worth. The company admitted that Budd reported inappropriate comments in September 2019 and took a leave of absence from October to December 2019. They confirmed placing her on paid administrative leave while investigating her December 2019 HR complaint. However, SkyWest denied allegations of workplace harassment, hostile work environment, and discriminatory behavior.

SkyWest Airlines argued that Budd’s complaint failed to state a valid claim for relief and that some claims fell outside the applicable limitation periods. They contended that Budd failed to mitigate her damages and that any injuries she suffered were caused by third parties outside their control. SkyWest described Budd’s claims as frivolous and groundless, asserting they were entitled to recover attorney’s fees and costs.

SkyWest challenged the sufficiency of Budd’s complaint, stating it lacked necessary details for them to determine all defenses. They reserved the right to assert additional defenses as more information became available. The company argued that remedies for Budd were limited under Title VII and requested dismissal of all claims with prejudice. SkyWest sought costs, attorney’s fees, and any other relief deemed appropriate.

Jury Verdict

On November 20, 2024, the jury determined that SkyWest caused damages to Budd and awarded her significant compensation. They granted $150,000 for past compensatory damages, including emotional pain, suffering, mental anguish, and loss of enjoyment of life. For future compensatory damages, the jury awarded $20,000 for the same categories. The jury also found punitive damages warranted, concluding that SkyWest failed to prove good-faith efforts to prevent workplace harassment. As a result, they assessed $2,000,000 in punitive damages against the company. In total, Budd received $2,170,000 in combined compensatory and punitive damages in a workplace harassment case.

Court Documents:

Available Upon Request