In Equal Emp. Opportunity Comm’n v. FCA US, L.L.C., No. 25-CV-10174, 2026 WL 1333761 (E.D. Mich. May 13, 2026), the court, inter alia, held that plaintiff sufficiently alleged a sex-based hostile work environment claim in violation of Title VII of the Civil Rights Act of 1964, and therefore denied defendant’s motion to dismiss and/or for a more definite statement.
From the decision:
The Court finds that the Complaint plausibly alleges that Defendant FCA US, LLC created a hostile work environment for its female production employees by employing supervisors who sexually harassed female employees and failing to respond adequately to complaints about sexual harassment.
A plaintiff who asserts a sexual-harassment-based Title VII hostile-work-environment claim must allege “ ‘sufficient factual content from which a court, informed by its judicial experience and common sense, could draw the reasonable inference’ that [she] was subjected to a hostile work environment.” Bruce v. Adams & Reese, LLP, 168 F.4th 367, 377–78 (6th Cir. 2026) (quoting Keys v. Humana, Inc., 684 F.3d 605, 610 (6th Cir. 2012)). A hostile work environment exists when a “workplace is permeated with discriminatory intimidation, ridicule, and insult that is sufficiently severe or pervasive to alter the conditions of the victim’s employment and create an abusive working environment.” Smith v. Rock-Tenn Servs., Inc., 813 F.3d 298, 309 (6th Cir. 2016) (quoting Harris v. Forklift Sys., Inc., 510 U.S. 17, 21 (1993)).
The hostile-work-environment claim in this case includes allegations concerning the treatment of the two individuals whose charges led to this civil action (Jasmine Robinson and Jasmine Harvey) as well as allegations concerning a larger class of women that the EEOC alleges was subjected to a hostile work environment based on sexual harassment. The Court will first address the sufficiency of allegations pertaining to the two charging individuals before turning to the adequacy of the EEOC’s allegations regarding a larger class.
The EEOC’s complaint plausibly alleges that Jasmine Robinson and Jasmine Harvey were both subjected to a hostile work environment based on their sex. This result is compelled by a recent Sixth Circuit decision that affirmed the denial of a motion to dismiss in Bruce v. Adams & Reese, LLP, 168 F.4th 367 (6th Cir. 2026). The plaintiff in Bruce was found to have adequately alleged a sexual-harassment-based hostile-work-environment claim against a law firm where she previously worked as a paralegal. See id. at 378–81. The plaintiff alleged, among other things, that a supervising attorney suggested that “she keep clients happy by visiting them ‘in a short skirt,’ that she [was] a ‘[h]oe,’ and that it would be ‘hot’ if she had sex on a desk in the office.” Id. at 378. The Sixth Circuit concluded that it was “certainly plausible that a young female paralegal would be humiliated and intimidated, and that her performance would be affected, by [such] persistent suggestions.” Id. The court further found that the complaint plausibly alleged that the harassment was pervasive in that the allegations suggested that the offending attorney “consistently and continually directed sexualized comments” at the plaintiff. Id.
The complaint here contains similar allegations to those found sufficient in Bruce. The EEOC alleges, for instance, that a supervisor (Harrison) “regularly and inappropriately touched [Jasmine] Harvey while she was working, leered at her in a sexual manner, and made offensive sexual comments to her.” (ECF No. 1, PageID.6, ¶ 18.) It includes specific examples—e.g., the supervisor would purposely “brush up against the back of [Harvey’s] thighs” and made comments such as “I want your panties on my desk by noon” and “Your body looks right in that outfit.” (Id. at PageID.6, ¶ 19.) It further alleges that another supervisor (Johnson) “purposely ha[d] inappropriate sexual conversations in [Jasmine] Robinson’s presence,” “constantly spoke about women ‘shaking their a[**]’ and ‘sucking d*ck,’ and asked Robinson and other female employees to “come over to his house for ‘gifts’ (meaning sex).” (Id. at PageID.7, ¶¶ 28–29.) The EEOC further alleges that, “On a daily basis, Johnson would come over to the area where Robinson worked and spoke loudly about sexual intercourse directly to her and to other women who were present.” (Id. at PageID.7, ¶ 30.) It also claims that Johnson “groped” Robinson’s “rear end” in April 2021 and, after she told him not to do that, “he continued to intentionally visit her work area and speak loudly about men and women engaging in sexual intercourse in her presence.” (Id. at PageID.8, ¶ 32.)
(Cleaned up.)
The court concluded that “[t]hese allegations support a plausible inference that Robinson and Harvey were both subjected to a hostile work environment based on their sex while employed at Defendant’s Mack Plant, in violation of Title VII.”