Katz v. Dole

Deborah Ann Katz is a former federal air traffic controller whose employment was terminated by the Federal Aviation Administration (FAA) in September, 1981, for alleged participation in an illegal strike against the FAA. Prior to that, on June 9, 1981, Katz, after exhausting her administrative remedies, began the present action in the United States District Court for the District of Columbia, naming the FAAs statutory superior, the Secretary of Transportation, as defendant. Katz complaint claimed that she had been subjected to sexual harassment and to disparate and adverse personnel actions amounting to gender discrimination in violation of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000e-16 (1981). The action was subsequently transferred to the United States District Court for the Eastern District of Virginia. At the close of the trial, that court found that Katz had not been the object of intentional discrimination on the basis of her sex and entered judgment for the Secretary. The court granted Katz limited relief on her prayer for a correction of her government employment files. Katz appeals. We conclude that Katz did make out a case of sexual harassment actionable under Title VII but find no error in the district courts handling of Katz disparate treatment claim. We therefore affirm in part and reverse in part.