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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Rolfs v. Home Depot U.S.A., Inc., 971 F. Supp. 2d 197 (2013)

Citation
Rolfs v. Home Depot U.S.A., Inc., 971 F. Supp. 2d 197 (2013)
Parent Document
Rolfs v. Home Depot U.S.A., Inc., 971 F. Supp. 2d 197 (2013)
Jurisdiction
New Hampshire (state)
Effective Date
2013-09-20

Other Sections in This Document (163)

Full Text

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. Specifically, Rolfs argues that "Kelly used his authority over [him] to impose unwarranted discipline to punish [him] and force him back into acquiescence — the quintessential quid pro quo sexual harassment.” PL’s Mem. of Law (doc. no. 30-1) 28. According to the First Circuit, "[q]uid pro quo sexual harassment is when a supervisor uses his superior position to extract sexual favors from a subordinate and, if rebuffed, retaliates by taking action that adversely impacts the subordinate’s employment.” Gerald, 707 F.3d at 20 (citation omitted). As Rolfs has not alleged that Kelly sought to extract sexual favors from him, his invocation of quid pro quo sexual harassment seems inapt.