Article: Title VII's retaliation jurisprudence: litigation despite Faragher and Ellerth.(sexual harassment claims)

The Supreme Court's analysis of hostile work environment and an affirmative defense for employers should be used also in employer retaliation cases

WHETHER because of highly publicized incidents or small-scale awareness programs organized by employers or unions, sexual harassment claims appear to have infinitely multiplied in the last few years.(1) Although this has led to a significant amount of case law, legislation and commentary, there still are areas that the courts and Congress are struggling to define.

The Supreme Court issued two holdings in 1998, Faragher v. City of Boca Raton(2) and Burlington Industries Inc. v. Ellerth,(3) in an effort to ...

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