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If lower court judges follow the Supreme Court's ruling in the
Vinson case, then women workers who bring sexual harassment
lawsuits on a hostile environment claim will have to be
prepared for the submission of evidence regarding their per-
sonal attire, manner, and sexual activities. Thus, more than 20
years after Title VII went into effect, the concept of sex dis-
crimination continues to be shaped through the litigation
process.


NOTES
1 Lin Farley, Sexual Shakedown ( New York: McGraw-Hill, 1978), xi,
15
2 Ibid., 20.
3 U.S. Congress, Senate Committee on Labor and Human Resources,
Sex Discrimination in the Workplace, 1981: Hearings before the Committee on
Labor and Human Resources, 97th Cong., 1st sess., 1981.
4 Bames v. Costle, 13 FEP 123 (D.C. D.C. 1974).
5 Ibid., 124.
6 Williams v. Saxbe, 413 F.Supp. 654 (D.C. D.C. 1976).
7 See Barnes v. Costle, 561 F.2d 983 (C.A. D.C. 1977); Come v. Bausch
and Lomb, Inc., 562 F.2d 55 (9th Cir. 1977); Miller v. Bank of America, 600
F.2d 211 (9th Cir. 1979); Williams v. Saxbe, 587 F.2d 1240 (C.A. D.C. 1978).
8 Barnes v. Costle, 561, F.2d 983, 992, ft. 68 (C.A. D.C. 1977).
.9">9 "Quid pro quo" cases include Williams v. Saxbe, 413 F.Supp. 654
(C.A. D.C. 1976); Barnes v. Costle, 561 F.2d 983 (C.A. D.C. 1977); and
Munford v. James T. Barnes & Co., 441 F.Supp. 459 (E.D. Mich. 1977). Courts
ruled that a hostile working environment constituted sexual harassment in
Bundy v. Jackson, 641 F.2d 934 (C.A. D.C. 1981); Henson v. City of Dundee,
682 F.2d 897 (11th Cir. 1982).
10 Bundy v. Jackson, 641 F.2d 934 (C.A. D.C. 1981); Henson v. City of
Dundee, 682 F.2d 897 (11th Cir. 1982); See EEOC Guidelines, 29 C.F.R.
1604.11 (a) ( 1980).
.11">11 For example see Come v. Bausch and Lomb, 390 F.Supp. 161 (D.C.
Ariz. 1975); Tomkins v. Public Service Commission, 422 F.Supp. 533 (D.C.
N.J. 1976); and Bundy v. Jackson, 641 F.2d 934 (C.A. D.C. 1981).
12 29 C.ER. 1604.11 (a) (3).
13 U.S. Congress, Senate Committee on Labor and Human Resources,
Sex Discrimination in the Workplace, 1981: Hearings before the Committee on
Labor and Human Resources, 97th Cong., 1st sess., 1981, 339.
14 ibid.

-77-

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Publication Information: Book Title: Litigation, Courts and Women Workers. Contributors: Karen J. Maschke - author. Publisher: Praeger Publishers. Place of Publication: New York. Publication Year: 1989. Page Number: 77.
    
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