What U.S. court ruling distinguished between two types of supervisor harassment?

The ruling that distinguished between two types of supervisor harassment is Burlington Industries Inc. v. Ellerth. This landmark decision provided significant clarification on how the law addresses sexual harassment in the workplace, particularly in relation to actions taken by supervisors.

The case established the distinction between "quid pro quo" harassment and "hostile work environment" harassment. Quid pro quo harassment occurs when a supervisor makes unwanted sexual advances or demands for sexual favors in exchange for job benefits (such as promotions or raises). On the other hand, hostile work environment harassment involves behavior that creates an intimidating, hostile, or abusive work atmosphere, which may or may not involve a request for sexual favors.

The ruling emphasized the importance of employer liability, stating that if a supervisor takes a tangible employment action against an employee, such as demotion or termination, the employer can be held liable. However, the case acknowledged that employers might have a defense if they can prove that they had appropriate policies and procedures in place to prevent and address harassment, and if the employee failed to utilize those resources.

This distinction made in the Burlington Industries case is critical for understanding workplace harassment laws, guiding how organizations must train employees and implement policies to prevent and address harassment effectively.