Kimberly Ross obtained summary judgment in federal court for one of her clients, an automobile dealership. An employee of the dealership received two phone calls of a sexual nature from her manager, in the middle of the night. When the calls were brought to the attention of the dealership, both the finance director and the owner severely reprimanded the manager and instituted a “zero tolerance” policy for him. No further harassment occurred but the plaintiff quit her job shortly thereafter. The court granted summary judgment in favor of the dealership based on the Faragher/Ellerth affirmative defense, finding that: 1) the company’s sexual harassment policy constituted an adequate preventative measure; 2) the corrective measures (severe reprimand) were reasonably calculated to keep the harassment from occurring again, as evidenced by the fact that no further incidents occurred; and 3) the plaintiff unreasonably failed to take advantage of the corrective opportunities offered to her (training at another store or transfer). Link to full decision.