Continental Can Co., Inc. v. State, 297 N.W.2d 241 (Minn. 1980)

Continental Can Co., Inc. v. State, 297 N.W.2d 241 (Minn. 1980) was the first coworker harassment case brought by Willie Ruth Hawkins, an African American woman who worked at the Continental Can Company in Eagan, Minnesota.

Starting in December of 1974, three of Hawkins’ white male co-workers repeatedly made explicit, sexually derogatory remarks and verbal sexual advances to Hawkins and touched her sexually. One of her coworkers, Cliff Warling, made racist and sexually abusive comment to Hawkins. Warling and other male coworkers told her that “a female has no  business in a factory” and “if a female would work [in] a factory, she has to be a tramp.”

Hawkins repeatedly complained to her supervisor but Continental did nothing. One supervisor told Hawkins that there was nothing he could do and that she had to expect that kind of behavior when working with men. In October 1975, the harassment of Hawkins escalated to physical violence. Warling approached Hawkins from behind while she was bending over and grabbed her between the legs. Hawkins complained immediately, but again Continental did nothing. A few days later, Hawkins’ husband came to the plant and confronted Warling, who denied the incident. When Mr. Hawkins returned later that evening to escort his wife home, they discovered that her car headlights were broken. Relations between the Hawkins and her coworkers deteriorated further, culminating in a coworker threatening Willie Ruth Hawkins with a gun in front of her children.

At that point, the Hawkins solicited the support of New Way Community Center and the Urban League, who threatened boycotts and adverse publicity if Continental did not respond. Continental then suspended two of the  harassers and held a plant meeting to inform all employees that Continental would not tolerate verbal or physical sexual harassment and discrimination. Fearing for her safety, Hawkins did not return to work and was later fired. She brought a lawsuit under state law and won, creating a precedent for the important principle that employer tolerance of hostile environment harassment by coworkers was sex discrimination.