Szwalla v. Time Warner Cable, LLC
The plaintiff, Ms. Szwalla, an account executive, sued her employer, Time Warner Cable, alleging sexual harassment, hostile work environment, and retaliation in violation of Title VII. Her claims stemmed from alleged inappropriate comments and actions by managers Paul Noyd and Cory Karanik, and subsequent reassignments and warnings regarding sales performance. Defendants moved for summary judgment, arguing they exercised reasonable care to prevent harassment and that Ms. Szwalla unreasonably delayed reporting. The court granted summary judgment for the defendants, finding that they established the Faragher/Ellerth affirmative defense against the hostile work environment claim due to their prompt response to reported harassment and Ms. Szwalla's unjustified delay in reporting. Additionally, the court found that none of the alleged retaliatory actions, individually or in aggregate, constituted a materially adverse employment action.