See also: Race Discrimination; Sex Discrimination
    A black woman claimed that a state Department of Transportation's State Highway Administration refused to hire her for two different positions that she applied for because of her race and sex, despite her being "highly qualified." She claimed that the employer's decision makers were biased and "pre-determined" that they would only hire white applicants for the jobs. A federal appeals court upheld the dismissal of the lawsuit, finding that the plaintiff failed to adequately allege any facts that supported her claims that the employer discriminated against her because she was African-American or female. An adequate complaint must allege more than a "sheer possibility" that an employer has acted unlawfully. McCleary-Evans v. Maryland Department of Transportation, #13-2488, 780 F.3d 582 (4th Cir. 2015).
     A white male employee of a state highway and transportation department claimed that his firing constituted race and sex discrimination. Rejecting these claims, the federal appeals court found sufficient evidence that the employer fired him for violations of its sexual harassment policy. The plaintiff failed to show that this was a pretext or that the defendants believed or should have known that the sexual harassment allegations were false. Moody v. Vozel, #13-3772, 771 F.3d 1093 (8th Cir. 2014).
    An African-American woman serving in the U.S. Coast Guard Housing Office at an air station claimed that she was denied a promotion to the job of housing manager there because of her race and her gender. The defendant was entitled to summary judgment because the plaintiff failed to create a genuine issue of material fact on her claim that the non-discriminatory reason given for choosing another candidate for the job was a pretext. Based on the evidence presented no reasonable jury could come to the conclusion that the plaintiff's qualifications so outweighed those of the white male who got the job that it was more likely than not that discriminatory animus on the basis of race and gender clinched the job for him. Her qualifications were, indeed, superior to his in some areas, but his were also superior to hers in other areas. Hicks v. Johnson, #13-1741, 2014 U.S. App. Lexis 11664; 123 Fair Empl. Prac. Cas. (BNA) 473 (1st Cir.).
     A male Cuban-American was not selected for a job with the Library of Congress Office of Diversity which was given to a female African-American applicant. He sued under Title VII, claiming race, sex, and national origin discrimination. After a jury found for the defendant employer, he appealed, arguing that the trial judge erred in instructing the jury that it had to find that discrimination was the "sole reason" for his non-selection in order to hold for him. He argued that "sole reason" was the wrong legal standard. The federal appeals court agreed that the term "sole reason" should not have been used, but upheld the jury verdict on the basis that "sole reason" had been further defined for them in the instructions as the "but for" cause. With that definition, the instructions adequately conveyed the law. Ponce v. Billington, #11-5117, 679 F.3d 840 (D.C. Cir. 2012).
     A federal appeals court has upheld the invalidation of a requirement that applicants for jobs with the fire department be local residents, agreeing with a finding that it has a disparate impact on African-American applicants. Statistical analysis indicated that the department should employ approximately sixty-five African-American firefighters, but under the residency rule currently employed only two. The department services five municipalities with heavy Hispanic populations. The residency requirement was not supported by a business necessity justification in that it was not linked to the minimum qualifications for firefighter jobs. The NAACP v. N. Hudson Regional Fire & Rescue, #10-3965, 2011 U.S. App. Lexis 24562.
     A 49-year-old Cape Verdean black female employee of a county sheriff's department failed to show that she had been subjected to age, gender, race or national origin discrimination when she was passed over for promotion to computer programming jobs that were given to two younger white employees, one male and the other female. One had a computer-related associate's degrees and both had years of experience in intranet/internet user interface development. While the plaintiff also had a similar associates degree, her experience in a computer-related job was eleven years ago, and her experience was with a now long outdated DOS-based computer system that is no longer used. Additionally, she received the lowest exam and interview scores. Her current position as a budget administrator did not involve any use of computer skills. The court agreed that she simply wasn't qualified for the position she sought. Goncalves v. Plymouth County Sheriff's Department, #10-2063, 2011 U.S. App. Lexis 20397, 113 Fair Empl. Prac. Cas. (BNA) 805 (1st Cir.).
     Two candidates for firefighter jobs who were placed on the eligibility list after written and physical fitness tests and interviews claimed they were not hired because one of them is a woman and the other Native American. Rejecting these discrimination claims, a federal appeals court noted that both of the plaintiffs ranked low on the eligibility list, and had failed to show that the reasons given for the decisions not to hire them were pretexts for discrimination. Several of the jobs filled were funded by the federal government under the Staffing for Adequate Fire and Emergency Response (SAFER) grant program, encouraging cities to recruit racial minorities and women. This, however, did not alter the result, and allegedly negative remarks about SAFER did not constitute direct evidence that discrimination had occurred. Torgerson v. City of Rochester, #09-1131, 2011 U.S. App. Lexis 10938;112 Fair Empl. Prac. Cas. (BNA) 613 (8th Cir.).
     Fifth Circuit reinstates a Title VII action brought by a terminated black female police academy trainee. An instructor allegedly told her that "she would not pass the academy, that he would do everything he could to get rid of her, and that he hoped he never had to see her face again." Williams v. City of Tupelo, #10-60679, 2011 U.S. App. Lexis 4035, 111 FEP. Cases (BNA) 1471 (Unpub. 5th Cir.).
     Fourth Circuit reinstates a bias action brought by a black female firefighter who was not promoted to captain. She twice had passed both a written test and an experiential assessment, had positive performance reviews, had served as an acting captain on numerous occasions without incident and had administrative and training experience. Because management gave shifting and inconsistent reasons for her rejection, it raised questions about whether the failure to promote her was a mere pretext for discrimination. Wesley v. Arlington Co., #08-2063, 2009 U.S. App. Lexis 26554, 107 FEP Cases (BNA) 1732 (Unpub. 4th Cir.).
     Federal appeals court rejects the discrimination and retaliation claims of a terminated African-American sheriff’s investigator. The retaliation claims failed because management had legitimate reasons for her discharge, including citizen complaints, disciplinary problems, and performance deficiencies. Ramsay v. Broward Co. Sheriff’s Office, #08-10474, 2008 U.S. App. Lexis 25406 (Unpub. 11th Cir.).
     "Title VII was enacted to prohibit discrimination on the basis of race, gender, and other legislatively enumerated grounds. It is not a statute intended to police standards of general fairness in the workplace, or even to protect against the firing of an employee in order to cover up wrongdoing by an employer." Lightner v. City of Wilmington, #071442, 2008 U.S. App. Lexis 22688, 104 FEP Cases (BNA) 1155 (4th Cir.).
     Study shows that job discrimination plaintiffs win only 15% of the time. "The most significant observation about the district courts' adjudication of these cases is the long-run lack of success for employment discrimination plaintiffs relative to other plaintiffs. Over the period of 1979-2006 in federal court, the plaintiff win rate for jobs cases (15%) was lower than that for non jobs cases (51%)." Employment Discrimination Plaintiffs in Federal Court: From Bad to Worse?, 3 (1) Harvard Law & Policy Review 1 at 30 (Winter 2009).
     Federal court declines to dismiss a suit against the NYPD alleging race, nationality, gender and disability discrimination, a hostile work environment and retaliation. The plaintiff was terminated two weeks after filing an EEOC complaint and a male officer, whom had failed to disclose psychological treatment on his job application, was not terminated. Rodriguez v. City of N.Y., #05-CV-5117, 2008 U.S. Dist. Lexis 9966 (E.D.N.Y.).
     Female black applicant who was rejected for employment as an immigration inspector because of prior her workplace misconduct and public drunkenness, failed to show that the use of background checks had disparate impact on blacks or women. Crawford v. Dept. of Homeland Security, 101 FEP Cases (BNA) 948, 2007 U.S. App. Lexis 19540 (5th Cir.)
     EEOC endorses arbitration and mediation over litigation to resolve workplace bias claims, citing the lower costs and fewer delays. Report: ADR in the Federal Sector EEO Process for FY 2006.
     Ohio Supreme Court upholds a program to add hiring preference points for firefighter candidates that successfully complete an apprentice program designed to increase diversity. IAFF L-136 v. Dayton Civil Serv. Bd., #2004-1103, 107 Ohio St.3d 10, 2005 Ohio 5826, 836 N.E.2d 544, 2005 Ohio Lexis 2672 (2005). [2006 FP Mar]
     Seventh Circuit rejects a gender and race lawsuit filed by a black female city employee, who was rejected for a superior job position, in favor of a white male. "We do not sit as a superpersonnel department where disappointed applicants or employees can have the merits of an employer's decision replayed." Blise v. Antaramian, No. 04-1908, 95 FEP Cases (BNA) 1459, 2005 U.S. App. Lexis 9980 (7th Cir. 2005). {N/R}
     EEOC applies new management guidelines to promote diversity and de-emphasize raw statistics when measuring the federal workforce. EEOC Management Directive 715.
     Appeals court rejects suit filed by two black male state employees because the agency head chose a white female to be the agency's business manager; she had a degree in business administration and accounting, was a Certified Public Accountant, had extensive experience in finance and accounting, and had served as the Chief Financial Officer for various businesses. Bankhead v. Knickrehm, #03-2356EA, 2004 U.S. App. Lexis 4621 (8th Cir. 2004). {N/R}
     EEOC adopts a new federal sector management directive that emphasizes general principles for achieving equal employment opportunity goals and agency self-assessments of their progress. Management Directive 715 (eff. Oct. 1, 2003). {N/R}
     A black female who received a pay raise that $658 smaller than that of a younger light-skinned black male colleague did not suffer an adverse employment action. Milligan v. Citibank, #00 Civ. 2793, 2001 U.S. Dist. Lexis 16105 (S.D.N.Y. 2001). [N/R]
     State parole officer's race and sex discrimination claims were time-barred; the court rejected her continuing violation claims. Weeks v. New York St. Div. of Parole, #00-0211, 273 F.3d 76, 2001 U.S. App. Lexis 23586, 87 FEP Cases (BNA) 161 (2nd Cir. 2001). [N/R]
      Federal court dismisses a 1983 suit against the chief and another, alleging that criminal charges were maliciously brought against two police employees who were charged criminally with the misuse of computers. Lyles v. Montgomery Co., #DKC 2000-2021, 162 F.Supp.2d 402, 2001 U.S. Dist. Lexis 18950 (D. Md. 2001). [2002 FP Mar]
     Federal appeals court affirms verdicts of $900,000 against a county, plus $300,000 in compensatory and $1,350,000 in punitive damages against two county officials, to be divided equally by three white county employees who proved that they had been subjected to disciplinary action because of their race. Lambert v. Fulton Co., #00-14272, 253 F.3d 588, 2001 U.S. App. Lexis 11761 (11th Cir.). [2001 FP 105-6]
     Federal appeals court rejects the discrimination claims of a terminated African American woman state trooper; appellate panel holds that the state had service-related reasons to dismiss her -- bad driving, poor anger management and untruthfulness. Bogren v. Minnesota, #99-3516, 236 F.3d 399, 85 FEP Cases (BNA) 67, 2000 U.S. App. Lexis 33574 (8th Cir. 2000). {N/R}
     Seventh Circuit upholds Title VII suits by hired "testers" -- persons who do not actually want the jobs applied for, but are seeking to end discriminatory practices. Kyles v. JK Guardian Security, #98-3652, 222 F.3d 289, 2000 U.S. App. Lexis 15542, 83 FEP Cases (BNA) 404 (7th Cir.). See also, EEOC Doc. 915-062, Policy Guide on Use of Testers in Employment Selection Process (1990); EEOC Doc. N-915.002, "Enforcement Guidance: Whether Testers Can File Charges and Litigate Claims of Employment Discrimination" (1996); FEP Manual (BNA) 405:6899 (2000). [2000 FP 140-1]
     Federal appeals court upholds content-based exam for Chicago police lieutenants, including an eligibility list based on test results, except for a small number of set-asides for minority candidates. Bryant v. Chicago, #99-1272, 200 F.3d 1092, 2000 U.S. App. Lexis 528 (7th Cir.). [2000 FP 122-3]
     Supreme Court denies an enhanced disability claim brought by a former NYPD officer, who claimed she was the victim of racial and gender bias. She then alleged the federal appeals court is corrupt and racketeer influenced. Brown v. N.Y.C. Police Dept., #99-7555, 1999 U.S. App. Lexis 30450; cert.den. #99-1352, 2000 U.S. Lexis 2605, 120 S.Ct. 1674 (4-17-2000). [2000 FP 90]
     Federal appeals court holds than employees who are seriously assaulted by a coworker because of their race or gender can sue for a Title VII hostile work environment. Smith v. Sheahan, No. 98-2445, 189 F.3d 529, 1999 U.S. App. Lexis 20279, 80 FEP Cases (BNA) 1071 (7th Cir. 1999). [2000 FP 58]
     White former police officer settles his age and race reverse discrimination suit for $650,000. Shaw v. City of Sacramento, #95-CV-01130, 37 (1833) G.E.R.R. (BNA) 1360 (E.D. Calif. 1999). {N/R}
     Federal appeals court rejects Dallas Fire Dept. affirmative action plan that passed over white and Native American male firefighters; no proof of race or gender bias since 1976 consent decree. Dallas Fire Fighters Assn. v. City of Dallas, #96-11138, 150 F.3d 438, 1998 U.S. App. Lexis 17850, 77 FEP Cases (BNA) 1025 (5th Cir.). [1998 FP 170-1]
     Promotion of subordinate who is romantically involved with her superior did not violate Title VII. Taken v. Okla., 125 F.3d 1366, 1997 U.S.App. Lexis 26999 (10th Cir). [1998 FP 11-12]
     Note: See King v. Palmer, 598 F. Supp. 65 (D.D.C. 1984), rev'd other grds., 778 F.2d 878 (D.C. Cir. 1985) where a Dept. of Corrections nurse was allowed to sue for sex discrimination because a superior favored another worker with whom he was having a sexual relationship. Most cases hold to the contrary, however.
     Divided appeals court rejects a Title VII retaliation suit by former employee. Robinson v. Shell Oil Co., 70 F.3d 325 (En banc, 4th Cir. 1995). [1996 FP 108] Note: Supreme Court reverses, see 519 U.S. 337, 117 S.Ct. 843, 1997 U.S. Lexis 690, 72 FEP Cases (BNA) 1856. [1997 FP 74]
     Univ. No. Car. agrees to pay $330,000 to settle claims brought by a black woman police officer who was allegedly denied a promotion and was subjected to retaliatory conduct for raising her discrimination claims. Edwards v. Univ. N.C., 33 (1629) G.E.R.R. (BNA) 1108 (8/14/95). {N/R}
     Title VII does not confer jurisdiction on the courts to review a management/executive decision to revoke a federal security clearance. Brazil v. U.S. Navy, 1995 U.S. App. Lexis 26038 (9th Cir. 1995). {N/R}
     Sheriff's deputies and dispatchers are "employees" under Title VII, and are not the personal subordinates of the sheriff simply because they serve at his pleasure. Johnson v. Bd. of Co. Cmsnrs., 859 F.Supp. 438 (D.Colo. 1994). {N/R}
     Issuance of reprimands for uncontested behavior did not violate equal protection. Redpath v. Overland Park, 857 F.Supp. 1448 (D.Kan. 1994). {N/R}
     State of New Jersey settles Justice Dept. suit alleging selection bias for corrections and law enforcement positions. State will pay $7,475,000 in back pay and benefits. U.S. v. St. of New Jersey, (D.N.J. 1994). [1994 FP 106]
     President signs the Civil Rights Act of 1991 which reverses seven Supreme Court decisions. Act covers collateral attacks of consent decrees, business necessity, jury trials where compensatory or punitive damages are sought, disparate impact, filing times, expert witness fees, extraterritoriality, judgment interest, mixed motive discipline and terminations, race norming of test scores, post-employment bias, and seniority system challenge time periods. Act reverses Martin v. Wilks, 109 S.Ct. 2180 (1989); Wards Cove Packing Co. v. Atonio, 109 S.Ct. 2115 (1989); West Va. Univ. Hospitals v. Casey, 111 S.Ct. 1138 (1991); EEOC v. Arabian Amer. Oil Co., 111 S.Ct. 1227 (1991); Price Waterhouse v. Hopkins, 490 U.S. 228, 109 S.Ct. 1775 (1989); Patterson v. McLean Credit Un., 109 S.Ct. 2363 (1989); Lorance v. A.T.&T. Technologies, 109 S.Ct. 2261 (1989). [1992 FP 9-11]
     DC Federal Court declines to apply 1991 Civil Rights Act retroactively. Van Meter v. Barr, 803 F.Supp. 444, 1992 U.S. Dist. Lexis 16507, 60 FEP Cases (BNA) 193 (D.D.C. 1992). [1992 FP 26 & 43-4]
     Ø Article: J. Ronzio, Esq. and G. Kiser, Esq., "The Civil Rights Act of 1991." 59 (5) The Police Chief (IACP) 11-12 (May 1992). A succinct summary of the changes.
     White male, who was dismissed for inefficiency after his black superior called him a "white token" and a "white faggot," loses his race and sex discrimination claim for lack of proof discriminatory factors motivated his termination. Young v. City of Houston, 906 F.2d 177 (5th Cir. 1990).
     Preservice agility tests for St. Paul Fire Dept. ruled discriminatory and unsupported by realistic job requirements. Minn. Dept. of Human Rts. v. City of St. Paul, Office of Admin. Hrgs. #8-1700-3224-2, 28 (1380) G.E.R.R. (BNA) 1143 (8/24/90).
     Consent decrees attempt to correct many wrongs within a total picture of discrimination. Individualized relief for a few is an insufficient basis to modify or set aside a broadly based consent decree. U.S. v. City of Chicago, 908 F.2d 197 (7th Cir. 1990).
     U.S. Supreme Court increases burden of proof on alleged victims of discrimination who claim disparate treatment. Mere fact they disproportionately hold lower paying pay positions is not proof of discrimination. Wards Cove Packing Co. v. Atonio, #87-1387, 109 S.Ct. 2115 (1989), reversing 827 F.2d 439 (9th Cir. 1987).
     New York's highest court upholds $15,000 award for mental suffering and reinstatement; white woman was forced to resign because of her race and sex. State Div. of Human Rights v. Co. of Onondaga Sheriff's Dept., 71 N.Y.2d 623, 528 N.Y.S.2d 802, 524 N.E.2d 123 (1988).
     Two demoted white officers win, two lose, reverse political discrimination suit against the Chicago police dept. jury awards $90,000. Luchtenberg v. City of Chicago, U.S. Dist. Ct. (N.D. Ill. 8/9/88).
     D.C. fire battalion chiefs prove reverse discrimination claims in deputy chief selection process. Dougherty v. Barry, 607 F.Supp. 1271 (D.D.C. 1985).
     White male police applicant wins reverse discrimination suit; city's affirmative action plan was deficient. Lilly v. City of Beckley, 615 F.Supp. 137 (S.D. W.Va., 1985).
     Federal appeals court rejects "reverse discrimination" claims in Detroit fire department; Memphis case distinguished. Van Aken v. Young, 750 F.2d 43 (1984).
     Justice Dept. joins in suit by white firefighters who are suing for "reverse discrimination." Wilks v. Arrington, U.S. Dist. Court, Birmingham (1985).
     City could pass over white with higher score and promote black captain; not "reverse discrimination'. Talbert v. City of Richmond, 25 FEP Cases (BNA)953, 648 F.2d 925 (4th Cir. 1981).
     White Berkeley firefighters win appeal of reverse discrimination suit; appellate court orders award of attorney fees. Hiatt v. City of Berkeley, 151 Cal.Rptr. 895 (App. 1979).
     White police officers in Detroit win "reverse discrimination" case; promotional quotas outlawed as discriminatory. Detroit Police Officers Assn. v. Young, 446 F.Supp. 979 (E.D. Mich. 1978).
     Reverse Discrimination. McDonald v. Santa Fe Train Transportation Co., 427 U.S. 273, 96 S.Ct. 2574 (1976).
     New Jersey court reverses racial hiring quota; condemns reverse discrimination as unconstitutional. Lige v. Town of Montclair, 134 N.J.Super. 277, 340 A.2d 660 (1975).
     Chicago agrees to mammoth $9 million back pay award to women, blacks and Hispanics for hiring and promotional discrimination. U.S. v. City of Chicago, U.S. Dist. Ct. (N.D. Ill. 3/25/88), DoJ Ref. 88-113.
     North Carolina fire dept. agrees to pay damages to rejected black applicants, to further minority recruitment and end practice of segregation in assignments and sleeping accommodations. U.S. v. City of Jacksonville, N.C., U.S. Dist. Ct. (E.D.N.C. 4/24/87).
     Long Island police sign consent decree; $508,000 in back pay claims and new testing procedures ordered. U.S. v. Suffolk Co., N.Y. (E.D.N.Y. 1986).
     Justice Department claims Little Rock Fire Dep't has failed to comply with their consent decree. U.S. v. City of Little Rock, Ark., U.S. Dist. Ct. (D.Ark. 1985).
     Kansas City loses in try to require police union to contribute on discrimination suit. Gray v. City of Kansas City, 603 F.Supp. 872 (D.Kan. 1985).
     Consent decree requires back pay awards to 87 unsuccessful police and fire applicants in Louisiana. U.S. v. City of Lafayette and Morgan City, La., U.S. Dist. Ct. (E.D. La. 1985).
     Federal Court rejects Justice Dept. claim police dept. failed to adequately recruit minorities and women; efforts cited. U.S. v. City of Yonkers, 609 F.Supp. 1281 (S.D.N.Y. 1984).
     Chief and others need not be named in EEOC complaint in order to be sued in federal court. Scott v. City of Overland Park, 595 F.Supp. 520 (D.Kan. 1984).
     Justice dept. notifies police and fire agencies under contract decree to comply with Memphis case.
     Justice department sues Las Vegas for sex and race discrimination in its metro police dept. U.S. v. Las Vegas Metropolitan Police Dept., et al., U.S. Dist. Ct. (D.Nev. 1985).
     Justice department files anti bias suit against Suffolk County, Long Island, police department -- nation's tenth largest. U.S. v. Suffolk Co. Police Dept., U.S. Dist. Ct. (E.D.N.Y. 1983).
     City could pass over white males to promote qualified females and minority applicants. Van Aken v. Young, 541 F.Supp. 448 (E.D. Mich. 1982).
     Consent decree in Arkansas calls for 20 percent blacks and 16 percent females in fire and police department. U.S. v. City of North Little Rock, U.S. Dist. Ct. (D.Ark. 1982).
     Federal appeals court sets aside decision that housing police must be paid same salary as city officers. Members of Bridgeport Housing Auth. Police v. City of Bridgeport, 646 F.2d 55 (2nd Cir. 1981).
     New Justice Dept. policy not to seek preferential hiring is reflected in New Hampshire settlement. U.S. v. New Hampshire State Police, U.S. Dist. Ct. (D.N.H. 1981).
     Memphis renews consent decree on fire and police hiring; progress noted. U.S. v. City of Memphis, U.S. Dist. Ct. Tenn. (1981).
     Federal court upholds Buffalo police and fire hiring goals. U.S. v. City of Buffalo, 24 FEP Cases (BNA) 313, 633 F.2d 643 (2nd Cir. 1980).
     Federal employment discrimination complaint cognizable although agency has less than 15 employees, if governmental entity has 15 or more employees. Owens v. Rush, 636 F.2d 283, 49 LW 2423, 24 FEP Cases 1563 (10th Cir. 1980).
     Federal appeals court condemns multiple choice tests for supervisory promotions; assessment center imperfect, but better choice. Firefighters Instit. for Racial Equal. v. City of St. Louis, 21 FEP Cases (BNA) 1140 (8th Cir. 1980).
     Consent decree on firefighter applicants; racial discrimination suit against 12 New Jersey cities settled. U.S. v. City of Jersey City et. al., U.S. Dist. Ct. (D.N.J. 1980).
     In a racial discrimination suit, the lack of sufficient sample size counteracts the significance of statistical disparity in the test results. Commonwealth v. Rizzo, 466 F.Supp. 1219 (E.D. Pa. 1979).
     San Francisco police hiring decree finally approved. Officers for Justice v. San Fran. Civil Serv. Cmsn., U.S. Dist. Ct. #6C-73-0657 & C-77-2884 (N.D. Cal.).
     Justice Department files motion to require Wisconsin fire department to employ female paramedics. U.S. v. City of Milwaukee, U.S. Dist. Ct. (E.D.Wis. 1979).
     Florida highway patrol and justice department sign consent decree; specific hiring goals for blacks, Hispanics and women set. U.S. v. Florida Highway Patrol, U.S. Dist. Ct. (N.D.Fla. 1979).
     Maryland state police agree to revised consent decree on black and female applicants. U.S. v. Maryland State Police, U.S. Dist. Ct. (D.Md. 1979).
     Federal court finds racial and sex discrimination practices in Buffalo fire and police departments; union's acquiescence created joint liability. U.S. v. City of Buffalo, 457 F.Supp. 612 (W.D.N.Y. 1978).
     See also: Citizenship Requirements; Sex Discrimination; Sexual Harassment and EEOC regulations at www.eeoc.gov/regs/