The passage of Title VII of the Civil Rights Act of 1964 marked the beginning of the movement towards awareness and enforcement of women\'s rights in the workplace. The movement has since led to a generation where the term \"sexual harassment\" has become part of the common vernacular. Title VII, however, provides less than clear guidance in the application of its sweeping prohibitions, and sexual harassment litigation has resulted in inconsistent results among courts. In this note, the author explores one notably dissonant area of sexual harassment claims-hostile work environment cases. Specifically, the Sixth and Tenth Circuits are directly split on the issue of whether the nature of the work environment where the gender discrimination is alleged to have occurred is a factor to be taken into account when evaluating a hostile work environment claim. In examining this issue in the context of blue-collar and white-collar working environments, the author outlines the disparities in the circuits\' approaches and the broader implications of these differences. The author ultimately concludes that the proper examination of Title VII hostile work environment sexual harassment claims must include consideration of the work environment as a whole. She provides a framework for applying the broader standard and also addresses employee acceptance of certain work site conditions, employer defenses, effects of future claims, and relevant counterarguments.
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