## Facts

- Paula Corbin Jones, an Arkansas state employee, sued William Jefferson Clinton (in his personal capacity) and Arkansas State Police officer Danny Ferguson for conduct alleged to have occurred in 1991, when Clinton was Governor of Arkansas.
- Jones alleged that, during a state-sponsored conference at a Little Rock hotel, Ferguson escorted her to the Governor’s hotel suite at Clinton’s request.
- Jones alleged Clinton made unwelcome sexual advances in the suite, including touching and exposing himself; she alleged she refused and left.
- Jones claimed that after the incident she experienced workplace hostility and altered job conditions, and later reputational and emotional harm from public denials of her allegations.
- Jones brought federal civil-rights claims under 42 U.S.C. § 1983 (equal-protection sex discrimination/sexual harassment) and 42 U.S.C. § 1985 (civil-rights conspiracy), and a state-law claim for intentional infliction of emotional distress (“outrage”).
- After the Supreme Court held that a sitting President is not constitutionally immune from civil litigation based on pre-office conduct and that the case need not be stayed, the case proceeded on the merits.
- The defendants moved for summary judgment on the remaining claims, and the district court resolved the case without trial.

## Issues

1. Whether Jones produced evidence sufficient to create a genuine dispute of material fact on § 1983 equal-protection sexual harassment theories (quid pro quo and hostile work environment).
2. Whether Jones produced evidence sufficient to support a § 1985 conspiracy to deprive her of equal protection.
3. Whether the alleged conduct satisfied Arkansas’s standard for intentional infliction of emotional distress (“outrage”).

## Decision

- The court granted summary judgment to Clinton and Ferguson on all remaining claims.
- On quid pro quo harassment, the court held Jones failed to show refusal of sexual demands resulted in a tangible job detriment or denial of a job benefit.
- On hostile work environment, the court held the alleged conduct was not sufficiently severe or pervasive, on this record, to alter the conditions of employment and create an abusive environment.
- On § 1985 conspiracy, the court held the record did not support an actionable conspiracy, and the failure of the underlying equal-protection claims defeated the conspiracy theory.
- On outrage, the court held the alleged incident, even if offensive and inappropriate, did not meet Arkansas’s “extreme and outrageous” threshold, and the evidentiary showing of emotional harm was inadequate.

## Legal Principles

- Summary judgment is appropriate when the record shows no genuine dispute of material fact and the movant is entitled to judgment as a matter of law.
- Quid pro quo sexual harassment under § 1983 (using Title VII framework) requires proof that rejection of sexual advances caused a tangible job detriment or denial of a job benefit.
- Hostile work environment liability requires harassment sufficiently severe or pervasive to alter employment conditions and create an abusive working environment.
- A § 1985 equal-protection conspiracy claim generally requires an underlying actionable deprivation and evidence of a concerted plan to violate protected rights.
- Arkansas outrage requires conduct so extreme and outrageous as to go beyond all possible bounds of decency, with a substantial evidentiary showing of resulting severe emotional distress.

## Conclusion

The district court dismissed the case on summary judgment, concluding that the evidentiary record could not support liability under § 1983 for quid pro quo or hostile-environment harassment, under § 1985 for a civil-rights conspiracy, or under Arkansas law for intentional infliction of emotional distress.


Jones v. Clinton, 990 F. Supp. 657 (E.D. Ark. 1998)