in place since March 2, 1987, six months prior to Giordano's initial complaint. Cagnina Aff. P 4. Prior to this time, the AAO conducted sexual harassment workshops for employees. Id.
Finally, in judging the effectiveness of remedial measures, courts also examine whether the harassment ended after such steps were taken. See Foster, 780 F. Supp. at 1039; see also Steele, 867 F.2d at 1316 ("Of special importance, Bucknole's harassment ended after the remedial action; the corporate employer, therefore, is not liable for Bucknole's actions under the doctrine of respondeat superior.")
On two occasions following her initial complaint, Giordano reported that Jackson sexually harassed her. In contrast, after her February 2, 1988 allegations against Ryerson and Seaman, Giordano did not file additional complaints against these men. The allegations against Jackson came to the AAO through memoranda dated December 2, 1987 and February 19, 1988. In each instance, the College conducted an informal investigation and found no evidence of harassment. Cagnina Aff. P 14-15.
Subsequently, by letter dated March 22, 1988, Giordano, through her attorney, complained directly to Acting Chief Ryerson that her rotating shifts periodically resulted in supervision by Jackson and continued harassment. Chief Ryerson, by letter dated April 8, 1988, assured plaintiff's attorney that Giordano was under his own command and at no time had Jackson been assigned to supervise Giordano. He also invited plaintiff to submit a formal request for a shift change, expressing a willingness to accommodate her. Giordano filed no additional complaints against Jackson.
Although harassment from Jackson apparently continued for six months after plaintiff's initial complaint against him, the Court is unwilling to rest liability on this factor alone. In the Court's view, the College promptly and adequately responded to Giordano's complaints. As a result, the College cannot be liable for sexual harassment based on a hostile environment claim.
For the reasons discussed above, the Court will grant defendant's motion for summary judgment as to plaintiff's sexual harassment claim based on a hostile environment theory and deny defendant's motion as to the quid pro quo sexual harassment claim.
An appropriate order is attached.
Dated: October 23, 1992
ALFRED M. WOLIN, U.S.D.J.
EDITOR'S NOTE: The following court-provided text does not appear at this cite in 804 F. Supp. 637.
In accordance with the Court's Opinion filed herewith,
It is on this 23 day of October, 1992,
ORDERED that the motion for summary judgment as to plaintiff's sexual harassment claim based on a hostile environment theory of defendant William Patterson College of New Jersey is granted; and it is further
ORDERED that defendant's motion as to the quid pro quo sexual harassment claim is denied.
ALFRED M. WOLIN, U.S.D.J.