Rolfs v. Home Depot, 2013 DNH 121 (2013)

Citation: Rolfs v. Home Depot, 2013 DNH 121 (2013)
Parent Document: Rolfs v. Home Depot, 2013 DNH 121 (2013)
Jurisdiction: New Hampshire (state)
Effective Date: 2013-09-20
Original Source: https://www.courtlistener.com/opinion/10693813/rolfs-v-home-depot/ ↗

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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. n o . 30-1) 2 8 .
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.

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