Caroline Manzo, a former real cast member of The Real Housewives of New Jersey, has sued Bravo, Forest Productions Inc., Warner Brothers Entertainment, NBC Universal Media, Shed Media US, and Peacock TV. As Ms. Manzo alleges, she was sexually harassed and assaulted by Brandi Glanville, another cast member, while filming an episode of The Real Housewives Ultimate Girls Trip, one of many spinoffs from the highly successful and enduring Real Housewives series. As Manzo alleges, the defendants “regularly ply the Real Housewives cast with alcohol, cause them to become severely intoxicated, and then direct, encourage and/or allow them to sexually harass other cast members because that is good for ratings.”[i]

If Ms. Manzo’s allegations are true, the Real Housewives franchise has real problems.

Facts

Ms. Manzo was an original cast member, first appearing on the show in 2009. She remained a cast member until 2014 when she left the show.[ii] Defendants later created The Real Housewives Ultimate Girls Trip, which Ms. Manzo joined in 2023. The alleged harassment occurred during the filming of an episode in Marakesh, Morocco.[iii]

Ms. Glanville, a former cast member of The Real Housewives of Beverly Hills, was cast for the Girls Trip show. As Ms. Manzo alleges, Ms. Glanville forcibly touched and kissed her on multiple occasions, among other things. Despite Ms. Manzo’s alleged cries for help, and being in front of a film crew on location, defendants allegedly did nothing to stop Ms. Glanville’s actions. Ms. Glanville continued to be present during shoots with Ms. Manzo despite her requests to the contrary. Eventually, Ms. Glanville was removed from the set.[iv]

Despite these allegations against Ms. Glanville, Ms. Manzo did not name Ms. Glanville as a defendant. In fact, Ms. Manzo included some choice quotes from Ms. Glanville which depict both women as victims of a hostile work environment, including the following:

• • “the producers ask you to do something and then you get in trouble for it!!!! The Producers need to follow the rules.”

• • “Producers may not shove the alcohol down our throats, but they sure do encourage it even in Morocco during the day where it’s illegal to drink.”

• • “JP they had pretty sure told me to rip his shirt off. . .I was doing what I was told.”

-Brandi Glanville, via Twitter[v]

As Ms. Manzo further alleged, defendants had “overwhelming” prior notice of Ms. Glanville’s “prior deviant sexual proclivities and sexually harassing conduct.”[vi] Ms. Manzo cited Seasons 2 through 5 of the Real Housewives of Beverly Hills, and Season 2 of the Ultimate Girls Trip as further evidence. These prior acts included attempting to kiss other castmates without their consent, unwanted and forcible touching, stating she was going “molest” another castmate, and using unwanted sexual language.[vii]

Will Defendants be Held Vicariously Liable for Ms. Glanville’s Alleged Sexual Assault of Ms. Manzo? Stay Tuned.

This case is in its early stages, and it remains to be seen whether defendants may be held vicariously liable for Ms. Glanville’s actions.  As the courts have explained, “[t]he doctrine of respondeat superior renders an employer vicariously liable for torts committed by an employee acting within the scope of the employment. Pursuant to this doctrine, the employer may be liable when the employee acts negligently or intentionally, so long as the tortious conduct is generally foreseeable and a natural incident of the employment.”[viii] There is, however, a recognized exception for sexual assault “perpetrated by an employee is not in furtherance of an employer’s business and is a clear departure from the scope of employment, having been committed for wholly personal motives.”[ix]

Thus, one of the big issues here is whether Ms. Glanville was acting “for wholly personal motives.”  If the allegations are true, Ms. Glanville was not acting for wholly personal motives—she was acting as directed. Defendants could have a real problem on that issue.  Furthermore, and even if defendants cannot be held vicariously liable, there may be other grounds for liability. As the courts have explained, “[i]n instances where an employer cannot be held vicariously liable for its employee’s torts, the employer can still be held liable under theories of negligent hiring, negligent retention, and negligent supervision . . . However, a necessary element of such causes of action is that the employer knew or should have known of the employee’s propensity for the conduct which caused the injury.”[x]

Ms. Manzo’s complaint contains 18 causes of action. To date, none of the defendants have appeared in the action. Stay tuned.

Takeaway

If Ms. Manzo’s allegations are true, this case presents a classic example of an employer failing to act in the face of a hostile work environment.  By failing to act—and even promoting an abusive environment– Defendants have exposed themselves to liability. Therefore, it is imperative that an employer, once it becomes aware of an employee’s propensity to commit, or the actual committal of, a sexually abusive act, to take corrective action.

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Sources

[i]Manzo v. Bravo, Index No. 160757/2024 (Sup. Ct. NY County) – https://iapps.courts.state.ny.us/nyscef/ViewDocument?docIndex=Gs9S8bugW2YWe9XxIcwIZQ==

[ii] Id.

[iii] Id.

[iv] Id.

[v] Id. at 4.

[vi] Id.

[vii] Id.

[viii] Montalvo v. Episcopal Health Services, Inc., 172 A.D.3d 1357, 1359 (2^nd Dept. 2019).

[ix] Id.

[x] Doe v Rohan, 17 AD3d 509, 512 (2nd Dept 2005) (emphasis added)