Yerry v. Pizza Hut of Southeast Kansas
Toby Yerry sued his former employer, Pizza Hut of Southeast Kansas, Inc., and shift manager Charles White, alleging sexual harassment and retaliation under Title VII and New York Executive Law, along with state common law claims. Yerry claimed White forced him to spank himself in a locked restroom. The court found that while the incident was severe enough to constitute a hostile work environment, Pizza Hut was not liable as it took prompt corrective action by suspending White immediately. Furthermore, Yerry's retaliation claim failed due to a lack of tangible adverse employment action, and White could not be held liable under New York Executive Law for aiding and abetting since no discrimination by the employer was found. Consequently, all federal and state law causes of action against Pizza Hut and White were dismissed, with remaining state law claims dismissed without prejudice.