John C. Ayres


Title VII of the Civil Rights Act of 1964 prohibits sexual harassment in the workplace. In a 2004 case of first impression, the Eighth Circuit Court of Appeals looked at an employer's affirmative defense against a hostile work environment claim involving a single incident of sexual harassment committed by a supervisor. The Eighth Circuit modified the test handed down by the Supreme Court in this situation. After outlining the historical background and rationale for imposing liability on employers for the actions of their supervisors, this Note will explore the logic behind the Eighth Circuit's interpretation of the Supreme Court test and analyze the implications of this interpretation on workplaces in the Eighth Circuit.

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