Appeals court affirms decision in Warren County sex discrimination, retaliation claim

A former Warren County Jail correctional officer whose claim against Warren County was dismissed by the U.S. District Court in Cincinnati in February 2020 also recently lost her appeal.

Shonda Million appealed the grant of summary judgment for the Warren County Sheriff’s Office on her claims of sex discrimination and retaliation under federal and Ohio law. On April 7, the U.S. Sixth Circuit Court of Appeals upheld the district court’s decision.

According to court documents, Million was a corrections officer at the Warren County Jail from September 2006 to January 2016.

The jail required at least two female corrections officers to work every shift. As a result, female officers sometimes had to work forced, female-only overtime and received unequal priority compared with male coworkers when bidding for shifts, according to court documents.

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Million challenged this policy as discriminatory in several internal grievances, beginning in 2012, and a 2013 charge with the Equal Employment Opportunity Commission. According to court documents, from March 2014 to December 2015, the jail disciplined her several times, audited her internet usage, initiated several sick leave reviews and revoked her position as a field training officer. Believing these actions were taken in retaliation for her discrimination complaints and would continue, she submitted a resignation letter in late December 2015 and worked her last day in early January 2016, according to court documents.

Million then filed the lawsuit alleging discrimination and retaliation.

The district court granted the jail’s motion for summary judgment and dismissed Million’s claims on grounds that the jail established its “bona fide occupational qualification” defense, and Million failed to show that she suffered a “materially adverse action.”

The three-judge panel of the appellate court affirmed both decisions of the district court, releasing their ruling on April 7.

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