## Facts

- Dr. Jean Y. Jew, a tenured associate professor in the University of Iowa College of Medicine’s Department of Anatomy, sought relief under Title VII for sex-based employment discrimination.
- For roughly a decade, faculty and colleagues circulated false, sexually explicit rumors that Jew had a sexual relationship with her department head and received professional benefits because of it.
- Coworkers directed gendered slurs at Jew (including “slut,” “whore,” and similar epithets), and sexually explicit cartoons and images implying a sexual relationship were displayed in workplace areas.
- The conduct harmed Jew’s professional reputation and affected workplace relationships; the rumors and related harassment were known within the department and at broader institutional levels.
- The University conducted internal inquiries; a panel concluded Jew had been defamed and sexually harassed, but remedial measures did not stop the conduct or repair its effects.
- In 1983, Jew was considered for promotion to full professor; the department vote was 5–3 against promotion, including votes by individuals linked to the rumor-spreading and derogatory conduct.
- Jew pursued internal complaints and external remedies beginning in 1984 and alleged that, thereafter, the University and certain actors subjected her to adverse treatment tied to her complaints.
- The case proceeded to a bench trial; earlier § 1983 claims against officials had been dismissed as time-barred.

## Issues

1. Whether persistent sexualized rumors, slurs, and related workplace conduct created a hostile work environment “because of sex” under Title VII.
2. Whether the denial of promotion to full professor was motivated by sex discrimination in violation of Title VII.
3. Whether the University retaliated against Jew for engaging in protected activity by complaining of sex discrimination and harassment.

## Decision

- The court entered judgment for Jew on her Title VII claims.
- The court found Jew proved a sex-based hostile work environment that altered the terms and conditions of her employment.
- The court found sex discrimination was a determining factor in the decision to deny Jew promotion to full professor.
- The court found the University retaliated against Jew for pursuing discrimination complaints.
- The court awarded back pay and ordered equitable relief aimed at correcting the discriminatory effects and preventing recurrence.

## Legal Principles

- Workplace harassment violates Title VII when it is because of sex and is sufficiently severe or pervasive to change the conditions of employment and create an abusive working environment.
- Sexualized rumors that attribute a woman’s professional standing to sexual conduct, coupled with gendered slurs and imagery, may constitute sex-based harassment even without sexual propositions.
- An employer may be liable for a hostile work environment when it knew or should have known of the harassment and failed to take prompt, effective remedial action reasonably calculated to stop it.
- A promotion decision violates Title VII when sex-based animus is a determining factor; evidence of discriminatory hostility by decisionmakers and pretext may support liability.
- Title VII prohibits retaliation when an employee engages in protected activity, suffers adverse consequences, and proves a causal connection between the two.

## Conclusion

The court held the University liable under Title VII for allowing long-running, sexualized defamation and gendered abuse to persist, for denying promotion based in part on sex discrimination, and for retaliating after the plaintiff complained, awarding monetary and equitable relief to remedy the violations.


Jew v. Univ. of Iowa, 749 F. Supp. 946 (S.D. Iowa 1990)