Sandra Bundy

Bundy, then a single mother of four children, joined the city government believing it offered opportunities for advancement and was hired by the District of Columbia Department of Corrections (DCDC) in 1970. She earned a yearly salary of $10,500, which was more than twice the starting salary of her old job, and was able to quit her second job as a night cashier. She was promoted several times and became a vocational rehabilitation specialist and helped former inmates find jobs.[2]

Bundy alleges that four supervisors sexually harassed her between 1972 and 1975, including Arthur Burton, James Gainey, Lawrence Swain and Delbert Jackson.[2][4]

Her supervisor Arthur Burton began making sexual comments about her in 1974, and asked her several times to leave work and go home with him, though Bundy said no every time. One time Burton called Bundy's home in the evening, though her number was unlisted, and then hung up on her when she refused to meet with him.[2]

After a time, Bundy's former colleague James Gainey became her new supervisor.[2] He began doing things in the office that made her uncomfortable, like patting her buttocks and calling her "fine Momma." He once invited her on a vacation, which she refused. He often asked her to sleep with him, and once said, "I've got a pocketful of money. Let's take the afternoon off to a motel and lay up." She said no to each of his advances.[2]

Bundy's supervisors regularly criticized her for taking too much time off and poor work performance, though she had never received such criticisms before rejecting their advances. At one point, Gainey threatened to fire her. Bundy later learned she'd been overlooked for a promotion while her male colleagues had moved up or been recommended. When she complained to her supervisors' superior Lawrence Swain, he told her that "any man in his right mind would want to rape you."[2][5] The next time she complained to him, he ignored her complaints and asked if she was dating anyone, adding, "Because if not, I want to take you to bed myself."[2][6] On the advice of a female colleague, she began keeping a diary and recording each incident.[2]

Bundy began having trouble sleeping, and lost weight. She often cried and once contemplated suicide. She started seeing a psychiatrist, and was prescribed medication for anxiety and depression.[2]

Years earlier, a colleague named Delbert Jackson had made several unsuccessful passes at Bundy and tried to get her to drink with him (she didn't drink), but when he was promoted to director of the DCDC she got desperate and went to him for help in April 1975. However, he and other boardmembers refused to concede she had a case.[2][6]

Bundy sought help from the Equal Employment Opportunity officers at the DCDC, but they cautioned her against bringing unwarranted complaints. Bundy's black co-workers criticized her for bringing forth the suit.[3] However, Bundy filed an informal and then a formal complaint.

When no action was taken, Bundy met with lawyer Robert Adler, who agreed to take on the case even though there was no legal precedent and Bundy didn't have much money to offer. Bundy filed suit in 1977 in the United States District Court for the District of Columbia seeking declaratory and injunctive relief.[7] Bundy v. Jackson was heavily covered by the press[8] and although it initially lost in court, after being appealed it became the first federal appeals court case to hold that workplace sexual harassment was employment discrimination and a violation of the Civil Rights Act of 1964.[1][3] Five years later the Supreme Court agreed with this holding in Meritor Savings Bank v. Vinson.