Hostile Work Environment

Sexual harassment is unwelcome conduct of a sexual nature, prohibited by Title VII of the Civil Rights Act of 1964, as it applies to employees, and Title IX of the [Page 449]Educational Amendments of 1972, as it applies to students. When harassing conduct is sufficiently severe or pervasive so as to impair the educational or employment benefits offered by educational institutions, it can be classified as hostile environment sexual harassment. A hostile environment may be created by sexually related pictures, jokes, e-mails, or other inappropriate behavior. Typically, a onetime occurrence of the conduct is not sufficient to create a hostile environment. Unlike quid pro quo harassment, a power relationship need not exist in order to create a hostile environment.