Erin Johnson worked at J. Walter Thompson (JWT), an international agency in New York, which is owned by WPP PLC. For the first six years, Johnson reported to former JWT chairman and CEO, Bob Jeffrey. But on January 1, 2015, Gustavo Martinez succeeded Jeffrey as JWT’s worldwide chairman and CEO. According to Johnson, Martinez, “made it impossible for her to do her job.” Because among other things, he harassed her. His alleged campaign of harassment included making jokes about rape and sexual assault, directed at both Johnson and others, physically touching and assaulting Johnson, making routine references to sex, making comments sexualizing and demeaning women’s bodies, and other inappropriate comments. Johnson complained about this behavior on numerous occasions to various high-ranking officials at JWT and WPP. According to Johnson, all of these complaints were for nothing. Johnson filed suit against JWT and WPP, among other claims, violating Title VII’s prohibition against sex discrimination, alleging a hostile environment based on sex.
The defendants moved to dismiss Johnson’s complaint for failure to state a claim upon which relief can be granted. The district court’s ruling on the motion follows.
Does Johnson have enough proof and facts of her claim for a hostile work environment in violation of Title VII and does it meet all the three elements required for this claim?