Were Burlington’s actions reasonable or in violation of Title VII? Or would a reasonable employee find Burlington’s actions materially adverse and therefore file a claim of discrimination?

Burlington Northern and Santa Fe Railroad Co. vs. White

Facts About Case:
Shiela White was the only woman working in a certain department at Burlington Northern & Santa Fe Railway Company’s Tennessee Yard. White complained that her supervisor, Bill Joiner, was telling her that women should not be working that certain department. Joiner was disciplined and White was reassigned to “track laborer” tasks, a step down from her previous position in the department as a forklift operator. White filed a first complaint to the Equal Employment Opportunity Commission (EEOC). White then filed a second complaint to the EEOC when her new supervisor, Percy Sharkey, suspended her without pay claiming insubordination by White. The case was investigated and she was reapplied into her position and given her missed salary. She then filed a Title VII action against Burlington claiming that their actions amounted to unlawful retaliation and therefore were in violation of Title VII. The jury found in her favor and the appeal court also affirmed the decision of the District Court in White’s favor of both retaliation claims. Burlington appealed to the U.S. Supreme Court.

Issue:
Were Burlington’s actions reasonable or in violation of Title VII? Or would a reasonable employee find Burlington’s actions materially adverse and therefore file a claim of discrimination?