## Facts

- Lois Robinson worked as a welder at Jacksonville Shipyards, Inc. (JSI) in a heavily male-dominated workplace with very few female skilled craftworkers.
- Nude and partially nude images of women were displayed throughout the workplace, including photographs, plaques, and sexually suggestive vendor calendars posted in work areas.
- Robinson complained to supervisors and management about the pornography; management knew of the displays but declined to adopt a policy prohibiting them.
- After Robinson complained about a sexually suggestive calendar posted in a trailer, “Men Only” was painted on the trailer door.
- The pornography coincided with sex-based verbal abuse and demeaning conduct, including vulgar comments, a supervisor’s rape-related “joke” and repeated taunts, and sexually explicit graffiti directed at Robinson in her work area.
- Robinson sued JSI and certain supervisors/managers under Title VII and Executive Order 11,246; the case was tried to the court.

## Issues

1. Whether pervasive workplace pornography, combined with sexually demeaning remarks and conduct, created a sex-based hostile work environment under Title VII even if the pornography was not targeted at a specific individual.
2. Whether JSI was liable where management knew of the pornography and harassment and failed to take effective corrective action.
3. Whether Title VII permitted injunctive relief restricting workplace pornography and, if so, whether such relief was consistent with the First Amendment.

## Decision

- The court entered judgment for Robinson, finding the workplace was permeated with sex-based intimidation and insult that altered the conditions of employment and created an abusive working environment.
- The court held JSI liable because management had actual and constructive knowledge of the conditions and failed to take prompt, appropriate remedial measures.
- The court issued injunctive relief requiring removal of sexually explicit materials that contributed to the hostile environment and requiring policies and training to prevent future harassment.
- The court rejected the argument that the injunction violated the First Amendment, concluding that Title VII could restrict workplace expression when it functioned as discriminatory harassment.

## Legal Principles

- A hostile work environment violates Title VII when discriminatory intimidation, ridicule, or insult is sufficiently severe or pervasive to alter employment conditions and create an abusive environment.
- The hostile-environment inquiry includes both subjective hostility (experienced by the plaintiff) and objective hostility (reasonable perception in the plaintiff’s position).
- Workplace pornography can constitute sex-based harassment when pervasive displays objectify or demean women and contribute to an environment that treats women as unequal employees.
- An employer is liable for a hostile environment when it knew or should have known of the harassment and failed to take effective corrective action.
- Injunctive relief under Title VII may require removing harassing materials and implementing preventive measures; regulating workplace pornography as part of such relief does not necessarily violate the First Amendment when limited to eliminating discriminatory conditions.

## Conclusion

The court held that pervasive workplace pornography, reinforced by sex-based comments and graffiti, created a Title VII hostile work environment for a female welder and that the employer’s knowledge and inaction supported liability; it also upheld targeted injunctive relief requiring removal of offending materials and adoption of anti-harassment measures.


Robinson v. Jacksonville Shipyards, Inc., 760 F. Supp. 1486 (M.D. Fla. 1991)