An employer’s federal obligation to investigate complaints of sexual harassment defeated the alleged harasser’s state law emotional distress claim stemming from the manner in which that investigation was conducted, the 2nd U.S. Circuit Court of Appeals ruled Jan. 26, partially reversing the trial court (Malik v. Carrier Corp., 2d Cir., Nos. 98-7109 and 98-7121, 1/26/00).

The investigation necessarily generated some emotional distress, Chief Judge Ralph K. Winter Jr. wrote for the court, but no more so than any other federally-mandated sexual harassment investigation.

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