YTHOMIT ONLY

directed at an individual, be actionable as sexual

harassment under Title VII? Yes—according to the

11th Circuit Court of Appeals. The plaintiff, Ingrid

Reeves, worked at a sales company, C.H. Robinson.

Reeves alleged that she was subjected to hearing her

male co-workers call other women names such as

“b***h,” “wh**e” and “c**t” on a daily basis. She also

claimed that there were repeated vulgar discussions

about female body parts and a pornographic image

of a woman in the office. Reeves complained to her

co-workers, her supervisor, and top company executives,

but the offensive conduct was “accepted and

tolerated.”

According to the 11th Circuit, “if Reeves’s account

is to be believed, C.H. Robinson’s workplace was more

than a rough environment—indiscriminately vulgar,

profane, and sexual. Instead, a just reasonably could

find that it was a workplace that exposed Reeves to

disadvantageous terms or conditions of employment

to which members of the other sex were not exposed.”

Moreover, the court stated that it was no defense to

assert “that the workplace may have been vulgar and

sexually degrading before Reeves arrived.”