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IRAC: Stoll v. Runyon
Issue
Issue 2
Cynthia Stoll was subjected to both quid pro quo sexual harassment and a hostile workplace environment at the Sacramento Post Office. In recognition of the psychological and physical trauma she had experienced, Stoll requested “back pay with interest and front pay until her normal retirement age, as well as the payment of her attorney's fees” (Stoll v. Runyon, p.1241). The Post Office refused to award front pay.
Issue 2
Stoll contended she was eligible for disability benefits due to the fact her psychological disturbances were trigged by her harassment.
Rule
Rule 1
The Office of Federal Operations (OFO) and the US Post Office both refused to award front pay, given that Stoll had been so psychologically debilitated by her experience she might not work again and argued that front pay in this instance would be tantamount to compensatory damages which were barred under Title VII at the time.
Rule 2
The USPO and OFO alleged that Stoll had filed her claim for disability benefits after the statute of limitations had expired.
Analysis 1
Compensatory damages were not permitted under Title VII.
Analysis 2
It was found that given that Stoll’s failure to respond in a timely manner for her disability benefits was a directly-caused symptom of her psychological incapacity, the court ruled that it was wrong for the USPO to effectively benefit from the disability that had been triggered by her employment, which rendered her unable to open her mail at times due to extreme anxiety (hence the delay in filing for disability benefits). Equitable tolling is permitted even when a client has a lawyer in the interests of justice. “The only claimed prejudice that the Post Office alleges is that it would not have paid Stoll's attorney's fees had it known that she intended to pursue her front pay claim,” but the Office would have been obligated to pay the claim anyway (Stoll v. Runyon, p.1242).
Conclusion
Stoll was awarded disability benefits, based upon the harassment she had experienced.
What I Learned
Statutes of limitation can be waived under good faith and extreme instances, such as this one, in which the defendant was prevented from benefiting from the psychological damage he or she triggered in the plaintiff.
Work Cited
Stoll v. Runyon, 1238-1243.
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