Campbell v. Florida Steel Corp.
This case addresses whether "cold-shoulder treatment" based on race or gender can constitute unlawful harassment under the Tennessee Human Rights Act and Title VII of the Federal Civil Rights Act, and the doctrine of constructive discharge. Plaintiff Brenda Campbell sued Florida Steel Corporation for sexual and racial harassment, which the employer initially remedied. Campbell then alleged "cold-shoulder treatment" and constructive discharge, a claim upheld by the trial court but reversed by the Court of Appeals. The Supreme Court affirmed the dismissal, concluding that while non-explicit conduct can be discriminatory, Florida Steel took reasonable remedial action given Campbell's failure to identify the perpetrators. The Court further clarified that for constructive discharge, conditions must be so intolerable that a reasonable person would resign, and found the evidence did not support Campbell's claim.