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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Quigley v. Winter, 598 F.3d 938 (2010)

Citation
Quigley v. Winter, 598 F.3d 938 (2010) 3.
Parent Document
Quigley v. Winter, 598 F.3d 938 (2010)
Effective Date
2010-03-16

Other Sections in This Document (232)

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3.     “Quid Pro Quo” Sexual Harassment
      Winter next contends the district court erred in denying his motion for judgment
as a matter of law on Quigley’s “quid pro quo” sexual harassment claim. “‘Quid pro
quo’ harassment occurs when housing benefits are explicitly or implicitly conditioned
on sexual favors.” Honce, 1 F.3d at 1089; cf. Ogden v. Wax Works, Inc., 214 F.3d
999, 1006 n.8 (8th Cir. 2000) (“To prevail on her [employment discrimination] quid
pro quo claim, [plaintiff] needed to prove (1) she was a member of a protected class;
(2) she was subjected to unwelcome harassment in the form of sexual advances or
requests for sexual favors; (3) the harassment was based on sex; and (4) her
submission to the unwelcome advances was an express or implied condition for