Psychological Injury Not Required for Sexual Harassment in "Abusive Work Environment"

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As the "NRPA Law Review" column begins its 14th year of publication in Parks and Recreation, it seems timely to revisit a topic which was examined in April 1983 in an article entitled, "Employer Liability for Sexual Harassment in the Workplace." This article cited the case of Henson v. City of Dundee, 682 F2d 897 (1982), in which the plaintiff alleged that the city's police chief "created a hostile and offensive working environment for women in the police station by subjecting them to numerous harangues of demeaning sexual inquiries and vulgarities." The specific issue is this case, therefore, was whether the plaintiff had alleged sufficient facts to establish that "her resignation was …