Redefining Reasonableness: Supervisory Harassment Claims in the Era of #metoo

In 2010, Robyn McEuen began working for a branch of AutoZone in Cordova, Tennessee.1 She excelled in her position and was promoted to the position of commercial specialist the following year.2 In 2012, McEuen was required to report to a new store manager, Gustavus Townsel, who was transferred to McEuen’s store from a different branch.3 Immediately thereafter, McEuen became the subject of disparaging, predatory, and inappropriate remarks and actions made by Townsel—Townsel would grab McEuen from behind, touch her genital region, and repeatedly proposition McEuen despite her continual efforts to rebuff his advances. 4 Townsel subjected McEuen to this harassment for months while her co-workers turned a blind eye to the conduct, reasoning that she must not have been that upset because she would have reported it if she were.5

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