## Facts

- Wilson Metal Casket Co. was a small manufacturing business owned and operated by Elmer Wilson.
- Employees Barbara Ellis and William Ellis (spouses) worked for the company.
- During William Ellis’s temporary medical leave, Wilson moved Barbara Ellis to a separate building and repeatedly sexually harassed her, including unwanted physical contact and sexual comments; the court found at least one coerced sexual act.
- After William returned, the harassment lessened but continued; William confronted Wilson by phone about the conduct.
- Wilson terminated both Barbara and William Ellis shortly after the confrontation.
- Wilson later hired Dawn McMullan; the district court found Wilson subjected her to similar sexual harassment, including following and fondling her in isolated areas and making sexual advances.
- After about three months, McMullan refused to return to work because of the harassment, and Wilson fired her.
- Barbara and William Ellis filed EEOC charges; McMullan did not file a separate charge.
- The EEOC sued under Title VII after investigating, and the district court (bench trial) found a pattern of severe sexual harassment and imposed monetary relief (including back pay and medical expenses tied to lost health coverage) and injunctive restrictions on Wilson’s interactions with female employees.

## Issues

1. Whether the EEOC could obtain victim-specific relief for Dawn McMullan, a non-filing employee, based on the Ellis charge and the scope of the EEOC investigation.
2. Whether Title VII “make-whole” relief permitted an award of Barbara Ellis’s medical expenses attributable to loss of employer-provided health coverage.
3. Whether awarding the full amount of accrued prejudgment interest was an abuse of discretion given the length of the administrative and litigation process.
4. Whether the injunction’s behavioral restrictions on Wilson were overly broad.

## Decision

- The Sixth Circuit affirmed the judgment imposing liability and most remedial relief.
- The court held that relief for McMullan was proper because her claims were similar to, and arose from the same general pattern and practices as, the timely charge that prompted the EEOC investigation.
- The court upheld the award of medical expenses as part of make-whole relief for lost benefits tied to the unlawful employment action.
- The court held the district court abused its discretion by awarding the full amount of prejudgment interest and modified the judgment to reduce prejudgment interest to 50% of the accrued amount.
- The court upheld the injunction as appropriately tailored to the proven pattern of harassment, including restrictions designed to prevent isolation of female employees and unwanted physical contact.

## Legal Principles

- Under the “single filing rule,” a non-filing employee may obtain relief in a Title VII action when a timely charge exists and the non-filer’s claims are similar and reasonably within the scope of the resulting EEOC investigation.
- Title VII authorizes make-whole relief that can include the value of lost employment benefits and medical expenses incurred because unlawful conduct caused loss of health coverage.
- Prejudgment interest in Title VII cases is an equitable remedy generally used to fully compensate victims, but the amount remains within the court’s discretion and may be reduced based on fairness considerations, including substantial delay not solely attributable to the defendant.
- Courts have broad equitable authority under Title VII to order injunctive relief aimed at preventing future violations, so long as the injunction is tailored to the misconduct proven at trial.

## Conclusion

The Sixth Circuit sustained broad Title VII remedies for severe sexual harassment by a company owner, permitted relief for a similarly situated non-filing victim within the scope of the EEOC investigation, upheld medical-expense recovery as make-whole relief, and approved tailored injunctive restraints, but reduced prejudgment interest as inequitable in light of extended delay.


Equal Emp. Opportunity Comm'n v. Wilson Metal Casket Co., 24 F.3d 836 (6th Cir. 1994)