On February 9, 2019, the Fourth Circuit in Parker v. Reema Consulting Services, Inc. reversed the district court by holding that an employer may be liable under Title VII for sex-based discrimination by participating in the circulation, and acting on, a false rumor that a female employee slept with her male boss to obtain a promotion.
In December 2014, Reema Consulting Services, Inc., (“RCSI”) hired Evangeline Parker as a clerk at one of its warehouse facilities. After several promotions, in March 2016, RCSI promoted her to Assistant Operations Manager. About two weeks after that promotion, she learned that several male employees were circulating an unfounded, sexually-explicit rumor that falsely portrayed her as having had a sexual relationship with a higher-ranking manager, Demarcus Pickett, to obtain her promotion. The rumor originated with another RCSI employee, Donte Jennings, and the highest-ranking manager at the warehouse facility, Larry Moppins, participated in spreading it.