## Facts

- Diane R. Williams, a Black woman, worked for the Department of Justice’s Community Relations Service (CRS) as a public information specialist (GS-8) after beginning in January 1972 under a temporary appointment later converted to career-conditional status with a probationary period.
- Williams’s immediate supervisor, Harvey Brinson, allegedly made persistent sexual advances, including requests for dates and suggestive communications.
- After Williams declined the advances, Brinson allegedly began criticizing her work, belittling her, and threatening adverse job actions.
- In September 1972, CRS terminated Williams, stating poor performance as the reason.
- The administrative record contained evidence suggesting a workplace pattern in which some male supervisors pursued female subordinates and women who acquiesced received more favorable assignments and advancement opportunities.
- Williams filed an internal EEO complaint alleging sex discrimination; an agency investigation initially found no discrimination.
- On administrative appeal, a Hearing Examiner found sex-based discrimination, but a Complaint Adjudication Officer rejected that conclusion on the view that the conduct was not actionable sex discrimination under Title VII.
- Williams sued under Title VII; after initially seeking a trial de novo, she stipulated to decision on the administrative record, and the parties filed dispositive motions.

## Issues

1. Whether adverse employment actions taken against a female employee because she refused a male supervisor’s sexual advances constitute discrimination “because of sex” under Title VII.
2. How the district court should evaluate conflicting administrative determinations on the record and allocate burdens in deciding whether Title VII was violated.

## Decision

- The court denied defendants’ request to dismiss and rejected their renewed summary-judgment position.
- The court held that retaliation or other adverse treatment imposed by a supervisor because a woman refused his sexual advances constitutes discrimination “because of sex” under Title VII.
- Reviewing the administrative record, the court credited findings supporting a causal link between Williams’s refusal of Brinson’s sexual demands, subsequent harassment, and her termination.
- The court concluded the agency’s contrary administrative disposition rested on an incorrect legal interpretation of sex discrimination and an improper allocation of the burden of proof.
- The court entered judgment for Williams based on the administrative record.

## Legal Principles

- Title VII’s prohibition of discrimination “because of sex” reaches employment conditions that require “sexual consideration” as a condition of favorable treatment or continued employment.
- Conditioning job benefits or avoiding job harms on acquiescence to sexual demands imposes a sex-based condition that operates as an artificial barrier to employment for one sex.
- Title VII is not limited to explicit sex classifications; it also covers coercive sex-conditioned terms, conditions, or privileges of employment.
- When record-supported administrative findings establish discriminatory causation, the employer must carry the burden to show by the clear weight of the evidence that the challenged action was non-discriminatory.

## Conclusion

The court treated a supervisor’s sexual-advance-based retaliation as actionable sex discrimination under Title VII and, based on the administrative record, ruled that Williams’s termination resulted from unlawful sex-based conditions imposed on female employees rather than legitimate performance grounds.


Williams v. Saxbe, 413 F. Supp. 654 (D.D.C. 1976)