On March 4, 1998, the U.S. Supreme Court decided Oncale v. Sundowner Offshore Services, Inc.,523 U.S. 75 (1998), which recognized a cause of action for workplace harassment under Title VII of the Civil Rights Act of 1964 when the harasser and the harassed employee are of the same sex. A little more than a year later, the initial impact of the opinion can be assessed. An analysis of the handful of cases that have relied on Oncaleshow how the opinion has affected federal and state courts’ approaches to harassment cases.

FEARS OF A CIVILITY CODE ARE UNWARRANTED

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