DISCRIMINATION IN EMPLOYMENT AND THE LAW

For your first assignment in this Module, you will be considering sexual harassment in the workplace, a topic which has garnered a great deal of attention recently. Review the required readings in the background material and then prepare a memo to yourself as follows:

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You are a newly assigned top HRM professional in your organization and you wish to review your organization’s sexual harassment policies and training. You will begin by identifying and explaining the key legal concepts in sexual harassment in the workplace. Then, using the background material and your own research, discuss aspects of recent developments in sexual harassment that are relevant to how your organization addresses sexual harassment in the workplace. Finally, identify and explain what you consider future developments in this topic will be and how your organization’s policies and training concerning sexual harassment will need to be adapted.

*****Assignment Expectations*****

Your memo should be 3 to 4 pages in length (not counting title and reference page) and should be submitted by the module due date.

*****CASE REQUIRED READINGS*****

Leskinen, E. A., Cortina, L. M., & Kabat, D. B. (2010). Gender harassment: Broadening our understanding of sex-based harassment at work. Law and Human Behavior, 35(1), 25-39. doi:10.1007/s10979-010-9241-5. Available in the Trident Online Library.

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Movieclips. (2015, August 11). Office Space (1/5) movie clip: Did you get the memo? (1999) HD [Video file]. Retrieved from 

Standard YouTube License.

Taub, A. (2017, November 29). How should we respond to sexual harassment? New York, NY: The New York Times. Available in the Trident Online Library.

U.S. Equal Employment Opportunity Commission. (n.d.). Sexual Harassment. Retrieved from

https://www.eeoc.gov/laws/types/sexual_harassment.cfm

******The criteria found in the grading rubric for this assignment****

  • Meets assignment requirements
  • Critical thinking
  • Writing and assignment organization
  • Use of sources and mechanics
  • Timeliness of assignment

4/10/2021 Sexual Harassment |

U.S. Equal Employment Opportunity Commission

https://www.eeoc.gov/sexual-harassment 1/2

U.S. Equal Employment Opportunity Commission

Sexual Harassment
It is unlawful to harass a person (an applicant or employee) because of that person’s
sex. Harassment can include “sexual harassment” or unwelcome sexual advances,
requests for sexual favors, and other verbal or physical harassment of a sexual
nature.

Harassment does not have to be of a sexual nature, however, and can include
o�ensive remarks about a person’s sex. For example, it is illegal to harass a woman
by making o�ensive comments about women in general.

Both victim and the harasser can be either a woman or a man, and the victim and
harasser can be the same sex.

Although the law doesn’t prohibit simple teasing, o�hand comments, or isolated
incidents that are not very serious, harassment is illegal when it is so frequent or
severe that it creates a hostile or o�ensive work environment or when it results in an
adverse employment decision (such as the victim being fired or demoted).

The harasser can be the victim’s supervisor, a supervisor in another area, a co-
worker, or someone who is not an employee of the employer, such as a client or
customer.

Employer Coverage

15 or more employees

Time Limits

https://www.eeoc.gov/

4/10/2021 Sexual Harassment | U.S. Equal Employment Opportunity Commission

https://www.eeoc.gov/sexual-harassment 2/2

180 days to file a charge (https://www.eeoc.gov/employees/charge.cfm)
(may be extended by state laws)

Federal employees have 45 days to contact an EEO Counselor
(https://www.eeoc.gov/federal/fed_employees/complaint_overview.cfm)

For more information, see:

Facts About Sexual Harassment (https://www.eeoc.gov/fact-
sheet/facts-about-sexual-harassment)
Title VII of the Civil Rights Act of 1964
(https://www.eeoc.gov/laws/statutes/titlevii.cfm)
Regulations: 29 C.F.R. Part 1604.11
(http://www.gpo.gov/fdsys/pkg/CFR-2016-title29-vol4/xml/CFR-2016-
title29-vol4-part1604.xml)
Policy & Guidance
(https://www.eeoc.gov/laws/types/sexual_harassment_guidance.cfm)
Statistics
(https://www.eeoc.gov/eeoc/statistics/enforcement/sexual_harassment.cfm)

https://www.eeoc.gov/employees/charge.cfm

https://www.eeoc.gov/federal/fed_employees/complaint_overview.cfm

https://www.eeoc.gov/fact-sheet/facts-about-sexual-harassment

https://www.eeoc.gov/laws/statutes/titlevii.cfm

http://www.gpo.gov/fdsys/pkg/CFR-2016-title29-vol4/xml/CFR-2016-title29-vol4-part1604.xml

https://www.eeoc.gov/laws/types/sexual_harassment_guidance.cfm

https://www.eeoc.gov/eeoc/statistics/enforcement/sexual_harassment.cfm

  • How Should We Respond to Sexual Harassment?
  • Taub, Amanda . New York Times (Online) , New York: New York Times Company. Nov 29, 2017.

    ProQuest document link

    ABSTRACT (ENGLISH)
    The legal system and social science offer principles to evaluate each case and to explain why this moment is so

    disorienting.

    FULL TEXT
    As accusations of sexual misconduct against famous men accumulate , the sheer quantity of dispiriting news is

    starting to create a confusing blur. The task of responding to sexual harassment and assault feels simultaneously

    more urgent and more daunting than ever.

    Society is out of practice at this task; the same culture of silence that protected harassers also suppressed the

    public response to their crimes. Many people struggle even to know which questions to ask, and worry that if they

    ask the wrong ones, they might become part of the problem.

    There is a temptation to simplify matters by viewing all harassers and their offenses as equally awful, or,

    alternatively, as equally misunderstood. But to be fair and effective, any system needs to make distinctions: to sort

    Harvey Weinstein from Roy Moore; and Louis C.K. and Matt Lauer from Al Franken.

    The legal system, while quite different from the court of public opinion, offers principles and reasoning that we can

    use to evaluate each case as it flares.

    Slippery slopes and consequences

    Until recently, all of those accused, no matter the severity of their offenses, faced the same consequences:

    generally none. Protected by their power and authority, they kept their careers and reputations intact.

    As that begins to change, some worry that we might bungle the job. “Taking harassment seriously also requires

    making serious distinctions,” Jonah Goldberg, a conservative columnist, wrote recently for The Los Angeles Times.

    “And yet Franken’s name is routinely listed alongside Moore’s and Weinstein’s.”

    Masha Gessen, writing in The New Yorker , worried we may be on the verge of a “sex panic.”

    Jane Curtin, a comedian who is a friend and former colleague of Mr. Franken’s, compared the current atmosphere

    to McCarthyism. “It’s just like the red menace,” she said in an interview with The Times. “You don’t know who’s

    going to be next.”

    Many of those accused have lost their jobs, but for the most part, they are not facing legal consequences. Yet

    principles borrowed from criminal law can help us analyze whether our response to their actions is just and fair.

    Criminal punishment tends to rest on two broad principles: the seriousness of the wrongdoing, and the

    perpetrator’s intent in committing the crime.

    Viewed through that lens, the accusations against Mr. Weinstein, which include rape, and Mr. Moore, who is

    accused of molesting teenage girls, are clearer-cut cases for punishment than those against, say, Louis C.K., who

    masturbated in front of adult women but did not touch them.

    It’s also important that courts do not consider only the moment of the crime itself in determining punishment. Our

    system also punishes defendants who threaten witnesses or obstruct justice, as well as others who help them do

    so. Here again, the accusations against Mr. Weinstein are especially extreme. According to a report by Ronan

    Farrow in The New Yorker, he hired ex-Israeli intelligence agents to intimidate victims and journalists into silence.

    Dana Min Goodman and Julia Wolov, two of the women who have accused Louis C.K. of misconduct, have said

    they stayed silent for years in part because of pressure from Dave Becky, Louis C.K.’s manager. Mr. Becky has

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    denied threatening them. But the women have said they feared that speaking would bring retribution.

    Accountability for harm

    The question of punishment is merely one factor in considering these cases. The wave of accusations has also led

    to demands that society recognize and repair the harm of sexual misconduct.

    Caroline Framke, a culture critic for Vox, called for an accounting of the “graveyard of potential cut short by

    careless cruelty.”

    The principles of civil law, which are intended to make victims whole and ensure that no one profits from

    wrongdoing, can offer useful guidance about what is fair, and what is necessary.

    A central principle is that the person at fault, not the victim, should bear the cost of the harms of wrongdoing. In

    law school, budding attorneys learn the “eggshell plaintiff” rule, which says that defendants are responsible for all

    of the harm they cause, even if the injuries were made more extreme because, say, the victim’s skull was as thin as

    an eggshell. Otherwise, the reasoning goes, the costs will fall on the victims —a more unfair outcome than holding

    perpetrators responsible for unexpectedly severe damages.

    It is now becoming clear that there is not a one-to-one correlation between the objective egregiousness of sexual

    misconduct and the damage it can cause.

    Louis C.K.’s actions may have been less extreme than Mr. Weinstein’s. But Ms. Goodman and Ms. Wolov have said

    they felt they could no longer work on projects involving him or his manager —a category that grew to include a

    large chunk of the comedy industry as Louis C.K.’s career took off.

    And the Emmy-award-winning writer Kater Gordon told The Information that when Matthew Weiner, her boss on the

    show “Mad Men,” told her that he “deserved to see her naked,” he undermined her confidence and ambition. (Mr.

    Weiner has said that he does not remember making that comment, and would not speak that way to a colleague.)

    Held up next to the allegations against Mr. Weinstein or Mr. Moore, those words may seem like a misdemeanor.

    But the harm was nevertheless severe, Ms. Gordon says, because she left the television industry, abandoning a

    promising career.

    Women are often told to grow a “thicker skin” and become less sensitive to harassment. But the eggshell plaintiff

    rule suggests a different conclusion: that the harassers should bear the costs of the harm they impose, even on

    “thin-skinned” victims.

    We must also consider harms that go beyond the immediate victims. Less diverse workplaces offer women fewer

    opportunities to find mentorship and achieve success; research suggests such workplaces are also less profitable.

    Holding particular harassers responsible for harms suffered by an entire industry or gender is difficult; there are

    too many contributing factors for it to be easy to apportion blame. Collective harm may be more suited to

    government- or society-level responses. But again, the harm is there. The question is who ought to bear the cost.

    Why it’s hard to think through these accusations

    As more men are tarred as bad actors, and once-cherished public figures become pariahs, imposing responsibility

    can feel uncomfortable, even alarming.

    People worry that we are sliding down a slippery slope to neo-puritanism, or in the throes of a witch hunt for sexual

    impropriety. Perhaps it will turn out that we are. But social science research suggests that this discomfort is a

    natural consequence of shifting social norms, not necessarily a sign that the changes are going too far.

    Humans are wired to conform to group judgments. Dan Kahan, a professor at Yale Law School, argued in an

    influential paper that we rely more on our peers’ opinions than on actual laws to determine what behavior is right

    or wrong.

    In the famous “conformity study ”by the researcher Solomon Asch, a majority of participants chose to select a

    clearly incorrect answer to a question rather than defy the group and cease being a peer in good standing.

    Partisanship was a crucial element in the issue of sexual assault during the 2016 presidential campaign, when

    Donald J. Trump was heard on tape boasting about grabbing women’s genitals. The ensuing public debate led

    many women to discuss their experiences for the first time.

    That was a shift away from the previous rules, in which victims stayed silent. But the partisan aspect of the

    episode meant that the new conversation about assault was still a form of group morality and a way to conform to

    group judgments. Opposing sexual assault became a way to call Mr. Trump unfit for office, and so it fit within the

    familiar context of partisan rivalry.

    But the more recent accusations —affecting Democrats as well as Republicans —have scrambled that partisan

    logic and made such group moral decision-making more difficult.

    Meanwhile, the old norms of gender roles and hierarchies have not disappeared, and may conflict with new

    demands for accountability. There is no safe harbor of conformity to be had.

    It would be convenient if doing the right thing were easy. But bringing long-hidden harms to the surface cannot

    help disturbing the status quo. Accounting for years of wrongdoing is costly, and dismantling hierarchies that

    fostered harm can lead, in the short term, to chaos. Now society must decide how many of those costs it is willing

    to bear.

    Source URL: https://www.nytimes.com/2017/11/29/upshot/sexual-harassment-response-legal-system-

    guidelines.html?partner=bloomberg

    Credit: AMANDA TAUB

    DETAILS

    Subject: Principles; Law schools; Sexual harassment; Society; Criminal law; Costs; Morality;

    Sex crimes; Partisanship; Accountability

    People: Goldberg, Jonah CK, Louis Curtin, Jane

    Company / organization: Name: New Yorker Magazine Inc; NAICS: 511120

    Identifier / keyword: Sexual Harassment Suits and Litigation (Civil) Women and Girls Weinstein, Harvey C

    K, Louis Franken, Al Trump, Donald J

    URL: https://www.nytimes.com/2017/11/29/upshot/sexual-harassment-response-legal-

    system-guidelines.html?partner=bloomberg

    Publication title: New York Times (Online); New York

    Publication year: 2017

    Publication date: Nov 29, 2017

    Section: upshot

    Publisher: New York Times Company

    Place of publication: New York

    Country of publication: United States, New York

    Publication subject: General Interest Periodicals–United States

    Source type: Blogs, Podcasts, &Websites

    Language of publication: English

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      How Should We Respond to Sexual Harassment?

    O R I G I N A L A R T I C L E

    Gender Harassment: Broadening Our Understanding
    of Sex-Based Harassment at Work

    Emily A. Leskinen • Lilia M. Cortina •

    Dana B. Kabat

    Published online: 27 July 201

    0

    � American Psychology-Law Society/Division 41 of the American Psychological Association 20

    10

    Abstract This study challenges the common legal and

    organizational practice of privileging sexual advance forms

    of sex-based harassment, while neglecting gender harass-

    ment. Survey data came from women working in two male-

    dominated contexts: the military and the legal profession.

    Their responses to the Sexual Experiences Questionnaire

    (SEQ) revealed five typical profiles of harassment: low

    victimization, gender harassment, gender harassment with

    unwanted sexual attention, moderate victimization, and

    high victimization. The vast majority of harassment vic-

    tims fell into one of the first two groups, which described

    virtually no unwanted sexual advances. When compared to

    non-victims, gender-harassed women showed significant

    decrements in professional and psychological well-being.

    These findings underscore the seriousness of gender

    harassment, which merits greater attention by both law and

    social science.

    Keywords Gender harassment � Sexual harassment �
    Working women � Well-being

    In 1964, Title VII of the Civil Rights Act codified the ille-

    gality of sex discrimination. However, it took another

    13 years for a federal appellate court to recognize sexual

    harassment as a form of sex discrimination (e.g., Barnes v.

    Costle, 1977). The prevailing view of sexual harassment,

    both then and now, sees unwanted sexual attention as ‘‘the

    quintessential harassment’’ (Schultz, 1998, p. 1710). Among

    legal scholars, a notable group has emerged who contend

    that this conceptualization is too narrow, arguing that

    ‘‘gender harassment’’ should be included in legal under-

    standings of sex-based harassment (Epstein, 1998; Franke

    1995, 1997, 2004; Growe, 2007; Hébert, 2005; Shultz, 1998,

    2003, 2006). Gender harassment refers to ‘‘a form of hostile

    environment harassment that appears to be motivated by

    hostility toward individuals who violate gender ideals rather

    than by desire for those who meet them’’ (Berdahl, 2007a,

    p. 425). In this article, we lend empirical support to the

    assertion that gender harassment is a serious form of sex

    discrimination that deserves more attention. Using survey

    data from two samples of working women, we demonstrate

    that most sexual harassment in traditionally male domains

    entails gender harassment in the absence of sexual advan-

    ces; we also show how these experiences are associated with

    negative personal and professional

    outcomes.

    Central Constructs

    In its broadest sense, sex-based harassment

    1

    refers to

    ‘‘behavior that derogates, demeans, or humiliates an indi-

    vidual based on that individual’s sex’’ (Berdahl, 2007b,

    E. A. Leskinen (&) � D. B. Kabat
    Department of Psychology, University of Michigan,

    530 Church Street, Ann Arbor, MI 48109, USA

    e-mail: leskinen@umich.edu

    L. M. Cortina

    Departments of Psychology and Women’s Studies,

    University of Michigan, Ann Arbor, MI 48109, USA

    1
    Psychology and the law have most commonly referred to this

    phenomenon as ‘‘sexual harassment.’’ However, Berdahl (2007b

    )

    makes a compelling case that ‘‘sex-based harassment’’ is a better

    construct label, as it emphasizes sex (in the sense of femaleness or

    maleness) rather than sexuality or sexual desire. We use both terms

    interchangeably—‘‘sexual harassment’’ and ‘‘sex-based harass-

    ment’’—to be consistent with the terminology of other literature but

    also encourage revision of that terminology.

    123

    Law Hum Behav (2011) 35:25–39

    DOI 10.1007/s10979-010-9241-5

    p. 644). Subsumed under this umbrella term are (at least)

    three related categories of behavior (e.g., Fitzgerald, Gelf-

    and, & Drasgow, 1995; Fitzgerald, Swan, & Magley, 1997).

    First, gender harassment refers to ‘‘a broad range of verbal

    and nonverbal behaviors not aimed at sexual cooperation but

    that convey insulting, hostile, and degrading attitudes about

    women’’ (Fitzgerald et al., 1995, p. 430). Examples of

    gender harassment include anti-female jokes, comments

    that women do not belong in management, and crude terms

    of address that denigrate women (e.g., referring to a cow-

    orker as a ‘‘dumb slut’’). By contrast, unwanted sexual

    attention involves expressions of romantic or sexual interest

    that are unwelcome, unreciprocated, and offensive to the

    recipient (e.g., unwanted touching, pressure for dates or

    sexual behavior). The third category is sexual coercion:

    bribes or threats that make the conditions of the victim’s

    employment contingent on her sexual cooperation (e.g.,

    offering a promotion in exchange for sexual favors, threat-

    ening termination unless sexual demands are met).

    Lim and Cortina (2005) elaborated on the relationships

    among gender harassment, unwanted sexual attention, and

    sexual coercion. They explained that ‘‘unwanted sexual

    attention, as the name suggests, represents unwelcomed,

    unreciprocated behaviors aimed at establishing some form

    of sexual relationship. One could argue that sexual coercion

    is a specific, severe, rare form of unwanted sexual attention,

    involving similar sexual advances coupled with bribery or

    threats to force acquiescence’’ (p. 484). In stark contrast,

    gender harassment communicates hostility that is devoid of

    sexual interest. Gender harassment can include sexually

    crude terminology or displays (for instance, calling a col-

    league a ‘‘cunt’’ or telling a sexually graphic joke about her),

    but these behaviors differ from unwanted sexual attention in

    that they aim to insult and reject women, not pull them into a

    sexual relationship. In colloquial terms, the difference

    between unwanted sexual attention/coercion versus gender

    harassment is analogous to the difference between a ‘‘come

    on’’ versus a ‘‘put down’’ (Fitzgerald et al., 1995).

    Gender harassment, unwanted sexual attention, and

    sexual coercion refer to behaviors rather than legal con-

    structs. That said, sexual coercion is roughly parallel to what

    the law calls quid pro quo harassment, whereas unwanted

    sexual attention and gender harassment together map onto

    the legal category of hostile environment harassment (e.g.,

    Fitzgerald et al., 1995; Fitzgerald, Drasgow, Hulin, Gelfand,

    & Magley, 1997). The next section elaborates on these legal

    understandings of sexual

    harassment.

    Legal Perspectives on Sexual Harassment

    Title VII prohibits employers from discriminating against

    any individual with regard to ‘‘compensation, terms,

    conditions, or privileges of employment, because of such

    individual’s…sex’’.2 When the federal courts first recog-
    nized sexual harassment as a Title VII violation, they were

    acting on cases in which women had lost jobs for failing to

    comply with their employers’ sexual demands, termed

    ‘‘quid pro quo harassment’’ (beginning with Barnes v.

    Costle, 1977). It took another decade before the U.S.

    Supreme Court would rule that ‘‘hostile work environment

    harassment’’ could constitute unlawful sexual harassment.

    In Meritor Savings Bank v. Vinson (1986), and later reaf-

    firmed in Harris v Forklift Systems, Inc. (1993), the Court

    described hostile environment sexual harassment as

    occurring ‘‘[w]hen the workplace is permeated with ‘dis-

    criminatory intimidation, ridicule, and insult’… that is
    ‘sufficiently severe or pervasive to alter the conditions of

    the victim’s employment and create an abusive working

    environment.’’ (Harris v Forklift Systems, Inc., 1993,

    p. 21). Hostile environment sexual harassment is the pri-

    mary focus of the current article.

    According to both Meritor and Harris, to create a leg-

    ally actionable hostile environment, the sexually harassing

    conduct must be either severe or pervasive. In Harris, the

    Court provided further guidance for determining whether a

    hostile work environment is present: the harassing conduct

    must pass both an objective test (a ‘‘reasonable’’ person

    would find it hostile or abusive) and a subjective test (the

    victim must have experienced it as abusive). Referring to

    the objective test, it added that ‘‘whether an environment is

    ‘hostile’ or ‘abusive’ can be determined only by looking at

    all the circumstances’’ (Harris v Forklift Systems, Inc.,

    1993, p. 22).

    Five years later, in Oncale v Sundowner Offshore Ser-

    vices, Inc. (1998), the Supreme Court elaborated on what

    should be considered when examining ‘‘all the circum-

    stances,’’ explicitly mandating attention to the larger social

    context. The Oncale decision also described types of

    conduct that might be considered ‘‘severe.’’ Particularly

    relevant to our article, it clearly stated that a motivation of

    sexual desire is not a prerequisite for establishing objective

    severity:

    …harassing conduct need not be motivated by sexual
    desire to support an inference of discrimination on

    the basis of sex. A Trier of fact might reasonably find

    such discrimination, for example, if a female victim

    is harassed in such sex-specific and derogatory

    terms…as to make it clear that the harasser is moti-
    vated by general hostility to the presence of women

    2

    In addition, Title VII prohibits discrimination based on race, color,

    religion, or national origin. Due to space constraints, this article only

    details how Title VII has been interpreted to prohibit sexual

    harassment.

    26 Law Hum Behav (2011) 35:25–39

    123

    in the workplace. (Oncale v Sundowner Offshore

    Services, Inc., 1998, p. 80).

    Despite this last development in judicial interpretations of

    Title VII, the prevailing legal conception of sexual harass-

    ment remains a highly sexualized one, in which sexually

    advancing or threatening conduct is seen as ‘‘the essence of

    harassment’’ (Schultz, 1998, p. 1716). The harassing

    behaviors alleged in Oncale, although recognized as moti-

    vated by hostility rather than desire, still involved sexually

    predatory behavior (e.g., sodomy with a bar of soap, threa-

    tened rape). The Supreme Court has never clearly stated

    whether the harassing conduct itself (as opposed to the

    motivation for the conduct) must involve some form of

    sexual advance to violate Title VII. Some appellate decisions

    have rejected this requirement of sexualized content; for

    example, in Williams v. General Motors Corp. (1999), the

    Sixth Circuit Court of Appeals stated that: ‘‘harassing

    behavior that is not sexually explicit but is directed at women

    and motivated by discriminatory animus against women

    satisfies the ‘based on sex’ requirement.’’ The federal bench,

    however, is far from unanimity on this issue. In the same

    Williams v GMC (1999) case, one judge filed a dissenting

    opinion, arguing vehemently that ‘‘…Title VII does not
    proscribe ‘anti-female animus’ at all’’ and ‘‘the broad new

    standard my colleagues have conjured here is not a correct

    application of Title VII sex discrimination law presently on

    the books.’’ Some courts routinely either dismiss hostile

    environment cases that do not involve sexual conduct, or

    they ‘‘disaggregate’’ sexual from nonsexual conduct and

    then deem the latter to be irrelevant to a hostile environment

    claim (see Franke, 2004, Growe, 2007, and Schultz, 2006 for

    various post-Oncale case examples). Thus, the privileging of

    the sexual advance in sexual harassment law continues.

    To summarize, on many occasions the federal judiciary

    has indicated, implicitly and explicitly, that offensive

    behavior must reference sexuality to constitute unlawful

    sex-based harassment. As a result, gender harassment

    involving no sexual advances routinely gets neglected by

    the law. This occurs even when the behavior fits all other

    characteristics of a legally actionable hostile environment:

    occurring ‘‘because of’’ the victim’s sex (interpreting

    ‘‘sex’’ to mean femaleness rather than sexuality); being

    ‘‘severe or pervasive’’ enough to adversely change the

    conditions of her employment; and creating a work envi-

    ronment that a ‘‘reasonable’’ person would find hostile or

    abusive, and that the victim herself finds as such. Promi-

    nent legal scholars have critiqued the exclusively sexual

    view of sex-based harassment, arguing for instance that

    ‘‘most harassment is not designed to achieve sexual grati-

    fication. Instead, it is used to preserve the sex segregation

    of jobs by claiming the most highly rewarded forms of

    work as masculine in composition and content’’ (Schultz,

    2006, p. 22; see also Epstein, 1998; Franke, 1995, 1997,

    2004; Growe, 2007; Shultz, 1998, 2003). At the same time

    that these issues have been debated in law reviews, an

    empirical literature on sexual harassment has developed in

    psychology. How has psychological science made sense of

    harassment based on sex and gender?

    Psychological Research on Sexual Harassment

    In psychology, researchers have examined lay perceptions

    of sexual harassment more than any other aspect of sexual

    harassment. These perceptions have differed over time,

    between men and women, and across cultures (Cortina &

    Berdahl, 2008; Rotundo, Nguyen, & Sackett, 2001). One

    finding has not changed, however: when researchers have

    compared perceptions of gender harassment versus

    unwanted sexual attention/coercion, participants have

    consistently rated the former as less severe, less offensive,

    and less likely to represent what they see as ‘‘sexual

    harassment’’ (e.g., Fitzgerald & Ormerod, 1991; Loredo,

    Reid, & Deaux, 1995; Tang, Yik, Cheung, & Choi, 1995).

    Quite separate from studies of sexual harassment per-

    ceptions within the lay public have been surveys of actual

    harassment experiences among working adults. As in the

    law, much of this work has concentrated on sexually

    advancing behaviors. For instance, the U.S. Merit Systems

    Protection Board (USMSPB) surveyed federal employees

    in 1980, 1987, and 1994 about their encounters with

    ‘‘sexual harassment,’’ defined as ‘‘uninvited and unwel-

    come sexual attention and/or behavior’’ (USMSPB, 1994,

    p. vi). Employees were asked to indicate the extent that

    they had experienced a list of specific acts, virtually all of

    which contained some form of sexual advance or sexual

    threat (from unwanted touching to pressure for dates to

    sexual assault). These surveys were well-executed and

    have had a major impact on the field. However, they

    neglected gender harassment.

    Unlike the USMSPB, some sexual harassment

    researchers routinely include questions about gender

    harassment in their surveys. This is true, for example, of

    the Sexual Experiences Questionnaire (SEQ), which has

    become the most widely used and validated measure of

    sexual harassment experiences (Fitzgerald et al., 1988;

    Fitzgerald, Magley, Drasgow, & Waldo, 1999; Stark,

    Chernyshenko, Lancaster, Drasgow, & Fitzgerald, 2002).

    Some versions of the SEQ even assess two subtypes of

    gender harassment—both ‘‘sexist’’ and ‘‘crude/offensive’’

    behavior (Stark et al., 2002). When SEQ researchers have

    divided harassment into its various subtypes, they have

    found gender harassment to be the most common (e.g.,

    Fitzgerald et al., 1988, 1999; Langhout et al., 2005;

    Schneider, Swan, & Fitzgerald, 1997). Little SEQ research,

    Law Hum Behav (2011) 35:25–39 27

    123

    however, has focused on experiences of gender harassment

    in isolation from other behaviors. Studies of sexual

    harassment prevalence and outcomes—using the SEQ and

    other instruments—typically collapse across the different

    facets of behavior for an overall measure of ‘‘offensive sex-

    related experiences in the workplace’’ (Fitzgerald, Swan

    et al., 1997, p. 9; for examples from other research pro-

    grams, see Barling, Rogers, & Kelloway, 2001; Culbertson

    & Rosenfeld, 1994; Richman, Shinsako, Rospenda, Flah-

    erty, & Freels, 2002). Although this practice permits

    examination of sexual harassment as a holistic phenome-

    non, and has yielded many important findings, it obscures

    the unique experience and impact of gender harassment.

    In addition to survey research, some psychologists have

    approached the study of sexual harassment from an

    experimental perspective. This work has also been char-

    acterized by an emphasis on sexual attention. For instance,

    lab studies have operationalized men’s sexually harassing

    behavior only as the sexual touching of women (Perry,

    Kulik, & Schmidtke, 1998; Pryor, 1987) or as sexually

    suggestive questioning (Woodzicka & LaFrance, 2005). In

    these examples and others, there was virtually no attention

    to gender harassment.
    3

    While gender harassment has been neglected in research,

    this behavior has also almost certainly gone unreported in

    organizations. Studies have found that victims who perceive

    the harassment as more severe are more likely to report their

    experiences to a superior (Bergman, Langhout, Palmieri,

    Cortina, & Fitzgerald, 2002). However, research into lay

    perceptions of sexual harassment (described above; e.g.,

    Fitzgerald & Ormerod, 1991; Loredo et al., 1995; Tang

    et al., 1995) suggests that gender harassment is widely

    believed to be inconsequential, or somehow less important

    than unwanted sexual attention in the workplace.

    Victims

    should, therefore, be less likely to see gender harassment as

    worthy of reporting, which means that organizational

    authorities should be less likely to intervene (Langhout

    et al., 2005). This makes it all the more imperative that

    social science bring gender harassment to the fore, so that it

    may be recognized as a legitimate and serious form of sex-

    based discrimination in the workplace.

    If It’s ‘‘Just’’ Gender Harassment, Why Should

    We Care?

    Because gender harassment has no explicit, sexually

    predatory component to it (unlike unwanted sexual

    attention or sexual coercion), it may seem less worthy of

    scientific or legal scrutiny. However, past research on

    everyday sexism has found that regular sexist interactions

    decrease psychological well-being and predict symptoms

    of psychological trauma (Berg, 2006; Swim, Hyers, Cohen,

    & Ferguson, 2001). For example, Swim and colleagues

    (2001) asked participants to keep track of instances of

    ordinary sexist behavior (e.g., anti-female jokes, comments

    reflecting gender stereotypes) observed or experienced in

    any life setting. They found that these everyday sexist

    encounters were associated with greater anger, anxiety, and

    depression. To explain these negative outcomes, Swim and

    colleagues (2001) argued that everyday sexism triggers

    feelings of stereotype threat, defined as ‘‘being at risk of

    confirming, as self-characteristic, a negative stereotype

    about one’s group’’ (Steele & Aronson, 1995, p. 797).

    Similar to everyday sexism, gender harassment may foster

    stereotype threat in women, especially those working in

    traditionally masculine domains. Gender harassment may

    be used to cue women that they are inadequate, out of

    place, and unable to perform at the level of men. The

    associated experience of stereotype threat could set off a

    cascade of negative outcomes in victims.

    Research has demonstrated that sexual harassment is

    linked with a wide range of victim outcomes (for recent

    reviews, see Berdahl & Raver 2010; Cortina & Berdahl,

    2008; Foote & Goodman-Delahunty, 2005). For instance,

    studies have found that sexual harassment is associated

    with decreased satisfaction with one’s job and professional

    relationships, loss of productivity, and increased turnover

    intentions and behaviors (e.g., Barling et al., 2001;

    Langhout et al., 2005; Sims, Drasgow, & Fitzgerald, 2005).

    Moreover, the consequences of sexual harassment are not

    constrained to the job site. Victims also report lower psy-

    chological well-being, more physical health problems, and

    even symptoms of traumatic stress (e.g., Culbertson &

    Rosenfeld, 1994; Fitzgerald, Swan et al., 1997; Richman,

    Shinsako, Rospenda, Flaherty, & Freels, 2002). By and

    large, however, this research has analyzed ‘‘sexual

    harassment’’ as a global phenomenon, failing to differen-

    tiate among the subtypes of sex-harassing behavior. It is,

    therefore, impossible to know from this work whether

    gender harassment by itself would have the same adverse

    implications for employee well-being.

    Hypotheses

    In sum, legal scholars have developed compelling theories

    about the importance of gender harassment, which we

    sought to test using large-scale survey research. In line with

    prior studies, we hypothesized that gender harassment,

    without unwanted sexual attention or coercion, would be

    3
    Notable exceptions exist, however, in the experimental literature on

    sexual harassment. For instance Schneider, Tomaka, and Palacios

    (2001) studied sexual harassment in the laboratory by exposing

    women to sexist comments—a clear form of gender harassment.

    28 Law Hum Behav (2011) 35:25–39

    123

    the most common form of sex-based harassment that

    women experience (Hypothesis 1). We also hypothesized

    that women would report negative professional and per-

    sonal outcomes, even when they ‘‘only’’ experience gender

    harassment (Hypothesis 2). We tested these hypotheses

    with survey data from women working in two male-dom-

    inated domains: the U.S. Military (Study 1) and federal

    legal practice (Study 2). Performing jobs that are highly

    nontraditional for their gender, women in these domains

    blur the boundaries between stereotypically ‘‘male’’ and

    ‘‘female’’ behavior. This makes them particularly vulner-

    able to being scorned and rejected (e.g., gender harassed)

    by colleagues who value rigid and clear distinctions

    between the sexes (Berdahl, 2007a, b).

    Study 1: The Military Survey

    Participants and Procedure

    Study 1 involved secondary analysis of survey data col-

    lected by the U.S. Military. This survey began with a non-

    proportional stratified, single stage random sample of

    active-duty members from all branches of the U.S. Military

    (Army, Navy, Air Force, Marines, and Coast Guard);

    women and people of color were oversampled. The initial

    sample contained 60,415 individuals, of whom 53,170

    were deemed ‘‘eligible’’ (reasons for ineligibility were

    various, such as inability to locate the sample member).

    These individuals were invited to complete surveys either

    on paper or online, and 19,960 usable surveys were

    returned (38% response rate). The current study focused on

    the 9,725 women who responded to the survey. Just over

    one-half of these women identified as White (55%), one-

    quarter as Black or African American (24%), and 11% as

    Hispanic or Latina. Forty-eight percent of the respondents

    reported some college, and 38% reported having at least a

    4-year college degree. The number of years of active ser-

    vice reported by members revealed a bi-modal distribution,

    with 43% reporting less than 6 years and 33% reporting

    10–20 years of active duty. For more information on this

    sample and procedures, see Lipari and Lancaster (2003).

    Measures

    All participants completed the 2002 Department of Defense

    Status of the Armed Forces Survey on Workplace and

    Gender Relations.4 Descriptive statistics, coefficient

    alphas, and intercorrelations for all variables analyzed in

    Study 1 appear in Table 1. For multi-item scales, we

    reverse-coded items as needed and then summed relevant

    items to create scale-scores; higher scores reflect greater

    levels of the

    underlying construct.

    Sex-Based Harassment. To assess unwanted sex-

    based experiences in the military, surveys contained an

    updated version of the Sexual Experiences Questionnaire-

    Department of Defense (SEQ-DoD) developed by Fitzgerald

    and colleagues (1999; see also Stark

    et al., 2002).

    Participants described how often over the prior 12 months

    they had experienced various forms of unwanted, uninvited

    ‘‘sex/gender related talk and/or behavior’’ involving military

    personnel, civilian employees, or contractors. They

    responded on a 5-point scale ranging from 0 = never to

    4 = very often. The measure consisted of 18 questions, in

    which there are four subscales: (1) gender harassment: sexist,

    (2) gender harassment: crude, (3) unwanted sexual attention,

    and (4) sexual coercion.

    The gender harassment: sexist subscale measured

    treatment that conveys explicit antipathy toward members

    of one gender. The subscale consisted of four items, such

    as ‘‘made offensive sexist remarks (for example, suggest-

    ing that people of your gender are not suited for the kind of

    work you do)’’ and ‘‘referred to people of your gender in

    insulting or offensive terms.’’ Four items also assessed

    experiences of gender harassment: crude behavior;

    although sexual on the surface, this behavior expresses

    animosity rather than attraction. Examples included:

    ‘‘made offensive remarks about your appearance, body, or

    sexual activities’’ and ‘‘made gestures or used body lan-

    guage of a sexual nature that embarrassed or offended

    you.’’ The unwanted sexual attention subscale consisted of

    six items, including ‘‘made unwanted attempts to establish

    a romantic relationship with you despite your efforts to

    discourage it’’ and ‘‘touched you in a way that made you

    feel uncomfortable.’’ The sexual coercion subscale con-

    tained four items, e.g., ‘‘implied faster promotions or better

    treatment if you were sexually cooperative’’ For more

    detail on this measure, including evidence of its high

    reliability and validity (see Fitzgerald et al., 1999; Stark

    et al., 2002).

    Psychological Well-Being. Psychological well-being

    was measured by the short, 5-item version of the Mental

    Health Inventory (MHI-5) (Viet & Ware, 1983). On a scale

    from 1 (little or none of the time) to 4 (all or most of the

    time), survey respondents rated how often they had

    experienced various psychological states over the prior

    4 weeks. Examples of psychological states included in this

    measure are: ‘‘felt calm and peaceful’’ and ‘‘felt so down in

    the dumps that nothing could cheer you up.’’ Researchers

    have found this scale to be reliable when used in the

    general population (Berwick et al., 1991).

    4

    This is a recurring survey; prior surveys took place in 1995 and

    1988.

    Law Hum Behav (2011) 35:25–39 29

    123

    Performance Decline Due to Poor Emotional

    Health. In order to determine whether participants

    experienced any difficulties during daily activities or

    work as a result of mental health problems, surveys

    included three questions adapted from the short-form

    health survey (SF-36) used in the Medical Outcomes

    Study (Ware & Sherbourne, 1992). Respondents rated how

    often over the past 4 weeks had they experienced a

    problem (such as ‘‘didn’t do work or other activities as

    carefully as usual’’) with their work or other activities ‘‘as a

    result of emotional problems (such as feeling depressed or

    anxious).’’ Response options ranged from 1 (little or none

    of the time) to 4 (all or most of the time).

    Performance Decline Due to Poor Physical

    Health. Surveys assessed health effects on work via

    four items adapted from the SF-36 (Ware & Sherbourne,

    1992). On a scale from 1 (little or none of the time) to 4 (all

    or most of the time), respondents rated how often over the

    past 4 weeks they had had problems with their work or

    other daily activities ‘‘as a result of their physical health.’’

    Examples of problems included: ‘‘were limited in the kind

    of work or other activities you do’’ and ‘‘had difficulty

    performing the work or other activities you do (for

    example, it took extra effort).’’

    General Health. Surveys asked respondents about

    their general health by having them respond to four

    statements on a scale of 1 (definitely false) to 4 (definitely

    true). Examples of statements included ‘‘I seem to get sick

    a little easier than other people’’ (reverse coded), and ‘‘my

    health is excellent.’’ These questions were adapted from the

    SF-36 (Ware & Sherbourne, 1992).

    Work Attitudes. Three measures tapped work

    attitudes. On a scale from 1 (strongly disagree) to 5

    (strongly agree), six items assessed coworker satisfaction;

    examples included: ‘‘you are satisfied with the

    relationships you have with your coworkers’’ and ‘‘there

    is very little conflict among your coworkers.’’ This scale

    was adapted from multiple sources, two items being taken

    from the Job Satisfaction Survey (Spector, 1997), three

    items adapted from the 1995 Armed Forces Sexual

    Harassment Survey (Edwards, Elig, Edwards, & Riemer,

    1997), and one item created for this survey.

    Six items adapted from the 1995 Armed Forces Sexual

    Harassment Survey (Edwards et al., 1997) measured work

    satisfaction. These items included statements such as ‘‘you

    like the kind of work you do’’ and ‘‘your work makes good

    use of your skills.’’ Organizational commitment was

    assessed using a modified version of Mowday, Steers, and

    Porter’s (1979) Organizational Commitment Question-

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    30 Law Hum Behav (2011) 35:25–39

    123

    willing to make sacrifices to help your Service’’ and ‘‘you

    are glad that you are a part of your Service.’’

    Turnover Intentions. In order to measure

    respondents’ thoughts and intentions of leaving military

    employment, five items were adapted from the 1999 Survey

    of Active Duty Personnel Form A (1999 ADS). Using a

    dichotomous yes/no scale, respondents indicated whether

    over the prior 6 months they had, for example, ‘‘Thought

    seriously about leaving the military’’ or ‘‘Discussed leaving

    and/or civilian opportunities with family or friends.’’

    Control Variables. We controlled for race, rank, and

    service branch in all outcome analyses. Respondents self-

    reported their race (coded 0 = minority and 1 = white).

    They also provided their rank (i.e., paygrade) at the time of

    the survey. Response options ranged from E-1 to E-9 for

    enlisted personnel; from W-1 to W-5 for warrant officers;

    and from O-1/O1E to O-6 or above for commissioned

    officers. When releasing these data to the public, the

    Defense Manpower Data Center (DMDC) collapsed these

    choices into five ordered categories: 1 = E1–E4; 2 = E5–

    E9; 3 = W1–W5; 4 = O1–O3; and 5 = O4–O6.

    Participants self-reported their service branch as either

    Army, Navy, Air Force, Marines, or Coast Guard.

    Results

    Profiles of Sex-Based Harassment

    In order to test our first hypothesis, we used k-means cluster

    analysis. k-means cluster analysis groups persons who are

    similar on specified variables (see Hartigan, 1975, for more

    information on this analytic approach). In the present study,

    the k-means analysis classified women by the type and

    amount of sex-based harassment they had experienced, as

    indicated on the SEQ-DoD. Included in this analysis were

    all women who reported experiencing at least one behavior

    on the SEQ-DoD at least one time over the previous

    12 months (n = 5,698). After standardizing these women’s

    scores on the four subscales of the SEQ-DoD, we requested

    two-, three-, four-, five-, and six-cluster solutions, and chose

    the five-cluster solution for further analysis. We based this

    decision on theoretical interest; we wanted to isolate women

    who had experienced primarily gender harassment without

    unwanted sexual attention or coercion. Profiles of means on

    the z-scored SEQ-DoD scales appear in Fig. 1.

    The largest group consisted of women who reported the

    lowest levels of harassment (Group 1; n = 3,933). As seen

    in Fig. 1, the experiences they described almost exclu-

    sively consisted of sexist behavior. The second-largest

    group (n = 1,161) contained women who had encountered

    both subtypes of gender harassment—sexist and crude—

    but very little unwanted sexual attention or sexual coercion

    (henceforth, this group will be referred to as Group 2, the

    ‘‘Gender Harassment’’ group). Group 3 (n = 429) dis-

    closed episodes of unwanted sexual attention, in addition to

    moderate levels of sexist and crude behavior. Group 4

    (n = 138) had encountered moderate levels of all types of

    harassment measured by the SEQ-DoD. Group 5 (n = 37),

    the smallest profile group, reported the most frequent

    harassment on all four subscales. In sum, 89.4% of

    harassment victims fell into Group 1 or 2, which described

    experiences of gender harassment but virtually no unwan-

    ted sexual attention or coercion. This pattern of

    victimization provides strong support for Hypothesis 1,

    which had predicted gender harassment (in the absence of

    sexual attention or coercion) to be the most common

    manifestation of

    sex-based harassment.

    -2

    0
    2
    4
    6
    8
    10

    12

    14

    Gender
    Harassment:

    Sexist

    Gender
    Harassment:

    Crude

    Unwanted
    Sexual

    Attention

    Sexual
    Coercion

    Z
    -S

    c
    o
    re
    s

    High Victimization (0.6%) –
    Group 5

    Moderate Victimization
    (2.4%) – Group 4

    Gender Harassment and
    Unwanted Sexual
    Attention (7.5%) – Group 3

    Gender Harassment
    (20.4%) – Group 2

    Low Victimization (69%) –
    Group 1

    Fig. 1 Profiles of harassment
    among military women

    (n = 5,698)

    Law Hum Behav (2011) 35:25–39 31

    123

    In addition to the five groups revealed through cluster

    analysis, we identified a sixth ‘‘Nonvictims’’ group, which

    contained all women who had responded ‘‘never’’ to all

    items of the SEQ-DoD. This group (n = 4,014) served as a

    comparison group in subsequent analyses.

    Table 2 reports demographic information for each of

    the profile groups. Using chi-square and ANOVA analy-

    ses, we found significant relationships between profile

    membership and race, v2 (5, N = 9711) = 55.34, p \
    .001; rank, v2 (10, N = 9704) = 159.00, p \ .001; years
    served, F (5, 9664) = 81.90, p \ .001; education level, F
    (5, 9621) = 32.14, p \ .001; and service branch, v2 (20,
    N = 9712) = 246.04, p \ .001. As seen in Table 2, the
    racial make-up of each profile group generally mirrored

    the overall sample. However, white respondents were

    slightly more likely to be in the Nonvictims Group, Group

    1 (Low Victimization), or Group 2 (Gender Harassment).

    Ethnic minority respondents were more likely to appear in

    Group 5 (High Victimization). Regarding military rank

    and group membership, commissioned officers were dis-

    proportionately likely to appear in Group 1 (Low

    Victimization), whereas enlisted personnel were dispro-

    portionately represented in Group 3 (Gender Harassment

    with Unwanted Sexual Attention). In terms of tenure (i.e.,

    years served) in the military, Nonvictims differed from all

    other groups by having served the greatest average number

    of years. Educational differences were most pronounced

    for the Nonvictims and Group 1 (Low Victimization), who

    had significantly higher educational levels than other

    groups.

    Outcomes of Sex-Based Harassment

    For theoretical reasons, we were most interested in out-

    comes for the group that had experienced primarily gender

    harassment (Group 2: the Gender Harassment group
    5
    ),

    which we compared to outcomes for women in the Non-

    victims group. A comparison of these two groups addresses

    the question of whether experiences of ‘‘just’’ gender

    harassment are associated with adverse consequences.

    In order to equalize cell sizes for this analysis, we ran-

    domly selected 1,000 women from the Gender Harassment

    group and 1,000 women from the Nonvictims group. Using

    multivariate analysis of covariance (MANCOVA), we then

    compared these two groups on the mental health, physical

    health, and organizational outcome variables. Covariates in

    this analysis were racial minority status, military rank, and

    service branch (to account for factors that could potentially

    affect harassment risk). We found a significant multivariate

    main effect of gender harassment on the collection of

    outcomes, Wilks’ Lambda = .81, F (8, 1822) = 52.06,

    p \ .001.
    As Table 3 shows, women in the Gender Harassment

    group scored significantly lower than the Nonvictimized

    women on all work attitudes (work satisfaction, coworker

    satisfaction, and organizational commitment). They also

    reported greater performance decline due to both physical

    and emotional health, and they described less overall

    psychological well-being and health satisfaction. Further-

    more, women in the Gender Harassment group disclosed

    greater thoughts and intentions of leaving their jobs.

    Cohen’s effect sizes (d) ranged from .22 to .79, averaging

    Table 2 Descriptive statistics for profile groups—Sample 1 (Military)

    Profile group Non-

    White

    percent

    Rank percent Years

    served

    Education Branch of service (%)

    Enlisted Warrant

    officer

    Commissioned

    officer

    Mean SD Mean SD Army Navy Marine
    corps

    Air

    Force

    Coast

    guard

    Nonvictims (n = 4,014) 47.0 69.8 3.6 26.5 2.28 1.07 2.21 0.70 26.6 21.1 11.0 34.4 6.9

    Group 1: Low Victimization

    (n = 3,933)
    42.1 68.2 3.3 28.4 2.07 1.06 2.21 0.70 28.9 21.4 13.8 26.8 9.1

    Group 2: Gender Harassment

    (n = 1,161)
    39.8 75.3 3.6 20.9 1.82 1.02 2.11 0.69 27.6 24.4 17.5 19.8 10.7

    Group 3: Gender Harassment

    & Unwanted Sexual

    Attention (n = 429)

    51.3 91.6 0.9 7.5 1.47 0.81 1.87 0.63 34.5 24.7 14.7 15.4 10.7

    Group 4: Moderate

    Victimization (n = 138)
    55.8 92.0 0.0 8.0 1.50 0.83 1.83 0.70 39.1 22.5 21.7 9.4 7.2

    Group 5: High Victimization

    (all types) (n = 37)
    70.3 91.9 0.0 8.1 1.65 0.95 1.83 0.57 56.8 2.7 29.7 5.4 5.4

    5
    We did not include Group 1 (the ‘‘low victimization’’ group) in

    outcome analyses, even though their experiences largely consisted of

    gender harassment, for two primary reasons. First, it is unlikely that

    the extremely low rates of harassing behavior described by this group

    would be seen as ‘‘sufficiently severe or pervasive’’ to be actionable

    under Title VII. In addition, we hope to avoid the criticism that we are

    ‘‘making mountains out of molehills’’ by foregrounding conduct that,

    while offensive, is transient and rare.

    32 Law Hum Behav (2011) 35:25–39

    123

    .48; the largest differences emerged for coworker satis-

    faction (.79), psychological well-being (.67), and work

    satisfaction (.58). These findings provided strong support

    for Hypothesis 2, which had predicted that experiences of

    gender harassment (alone) would be associated with neg-

    ative outcomes.

    To provide an additional point of comparison, we also

    combined Groups 3, 4, and 5 into a ‘‘

    Sexual Advance

    Harassment’’ group (n = 604). All of these women, unlike

    those in Groups 1 or 2, reported significant experiences of

    unwanted sexual advances at work, in the form of sexual

    attention and/or sexual coercion. We then conducted a

    second MANCOVA, comparing the outcomes of this Sex-

    ual Advance Harassment group to those of the Gender

    Harassment group and the Nonvictims group. There was a

    significant multivariate main effect of harassment-group-

    membership on the collection of outcomes, Wilks’

    Lambda = .77, F (16, 4748) = 40.82, p \ .001. As
    Table 3 shows, outcome means for the Gender Harassment

    Victims fell in between those for the Nonvictims and Sexual

    Advance Victims (although closer to the means of the latter

    group). According to follow-up Tukey tests, all outcomes

    for the gender-harassed women were significantly worse

    than those of the nonvictimized women. Moreover, Sexual

    Advance Victims showed significantly worse outcomes

    than Gender Harassment Victims, with two exceptions:

    there were no significant differences between the two

    groups on work satisfaction and turnover intentions.

    Study 2: The Attorney Survey

    Participants and Procedure

    We sought to cross-validate the results from Study 1 with

    secondary analysis of data collected from women working

    in a very different context: the legal profession. Participants

    were drawn from a stratified random sample of attorneys

    from a large federal judicial circuit. Surveys were sent to

    9,223 individuals, yielding a 53% response rate. The current

    study focused on the 1,425 women who responded to the

    survey. Most of these women were white (93%). They

    ranged in age from 24 to 79 years (M = 39.09, SD = 7.81).

    Sixty-eight percent of the women were married or part-

    nered, while 18% had never been married. These women

    were highly educated, all holding at least a Juris Doctor, and

    some holding additional graduate degrees. Similar to the

    military sample, they worked in a traditionally masculine

    occupation where women remain a minority. They com-

    pleted a paper-and-pencil self-report survey. More

    information about these participants and procedures appears

    in Cortina et al. (2002) and Lim and Cortina (2005).
    6

    Measures

    Table 4 displays the descriptive statistics, coefficient

    alphas, and intercorrelations for all variables from Study 2.

    Similar to Study 1, for multi-item scales, we reverse-coded

    items as needed and then summed relevant items to create

    scale-scores; higher scores reflect greater levels of the

    underlying construct.

    Sex-Based Harassment. Similar to Study 1, we used

    items from the SEQ developed by Fitzgerald et al. (1995,

    1988) to assess sex-based harassment. Participants

    described how often they had experienced a list of

    unwanted sexual or sexist behaviors over the past 5 years

    Table 3 ANCOVAs for physical health, mental health, and work outcomes—Sample 1 (Military)

    Outcome measured Nonvictims Gender Harassment

    Victims
    Sexual Advance

    Harassment Victims

    df F p

    Mean (SD) 95% CI Mean (SD) 95% CI Mean (SD) 95% CI

    1. Psychological well-being 16.76 (2.92) 16.58, 16.94 14.65 (3.43) 14.43, 14.86 13.62 (3.93) 13.31, 13.94 2, 2550 122.07 \.001
    2. Performance decline due to

    poor emotional health

    3.63 (1.49) 3.54, 3.73 4.47 (2.07) 4.34, 4.60 5.14 (2.51) 4.94, 5.34 2, 2562 75.91 \.001

    3. Health satisfaction 13.60 (2.10) 13.47, 13.73 13.04 (2.49) 12.89, 13.20 12.53 (2.62) 12.31, 12.74 2, 2550 24.06 \.001
    4. Performance decline due to

    poor physical health

    4.91 (2.09) 4.78, 5.04 5.62 (2.56) 5.46, 5.78 6.40 (3.16) 6.15, 6.66 2, 2555 37.90 \.001

    5. Coworker satisfaction 22.96 (4.50) 22.68, 23.24 18.89 (5.43) 18.55, 19.23 18.08 (5.73) 17.61, 18.54 2, 2532 169.93 \.001
    6. Work satisfaction 22.73 (5.44) 22.39, 23.07 18.96 (6.33) 18.56, 19.35 18.54 (6.62) 18.01, 19.07 2, 2554 89.16 \.001
    7. Organizational commitment 16.53 (2.66) 16.36, 16.70 15.49 (3.28) 15.28, 15.69 14.78 (3.35) 14.51, 15.05 2, 2555 29.15 \.001
    8. Turnover intentions 2.69 (1.80) 2.57, 2.80 3.44 (1.54) 3.35, 3.54 3.46 (1.58) 3.33, 3.58 2, 2558 53.49 \.001

    6
    Although drawing on the same larger dataset, these two past studies

    have different foci from each other and from the current article.

    Cortina et al. (2002) focused on gender differences in experiences of

    incivility and harassment in the legal profession. Lim and Cortina

    (2005) detailed how uncivil and harassing behaviors tend to co-occur

    and jointly affect personal and professional outcomes.

    Law Hum Behav (2011) 35:25–39 33

    123

    from judges, attorneys, trustees, marshals, court security

    officers, and court personnel. They responded on a 5-point

    scale ranging from 0 = never to 4 = many times. The

    measure consisted of nine questions, from which there are

    three subscales: gender harassment, unwanted sexual

    attention, and sexual coercion.

    The gender harassment subscale consisted of two items:

    ‘‘made offensive remarks or jokes about women in your

    presence?’’ and ‘‘publicly addressed you in unprofessional

    terms (e.g., ‘honey,’ ‘dear’)?’’
    7

    The unwanted sexual

    attention subscale contained four items, including:

    ‘‘attempted to establish a romantic or sexual relationship

    despite your efforts to discourage it?’’ Two items com-

    prised the sexual coercion subscale, such as, ‘‘implied

    more favorable treatment of you or your client if you were

    sexually cooperative?’’

    Job-Related Outcomes. We used a three-item scale

    (a = .74), developed for the purposes of this survey, to
    measure attorneys’ intentions to change careers (e.g., ‘‘I

    often think about leaving federal litigation’’). We measured

    job stress with three items (a = .75), such as ‘‘my expe-
    riences working in the federal court are more stressful than

    I’d like.’’ Finally, in order to assess professional relationship

    satisfaction, we used a three-item scale (a = .76) that
    consisted of items such as ‘‘in general, I am satisfied with my

    professional relationships with other attorneys in federal

    court.’’ For all three scales, response options ranged from 1

    (strongly disagree) to 5 (strongly agree).

    Control Variables. We controlled for race and job

    tenure in outcome analyses. Respondents self-reported

    their race (coded 0 = minority and 1 = white). They also

    reported the number of years they had actively practiced

    law, including clerkships. Response options were 1

    (0–5 years of practice), 2 (6–10 years of practice), 3 (11–

    20 years of practice), 4 (21–30 years of practice), and 5

    (31 ? years of practice); we collapsed response options 4

    and 5 due to the small number of women who chose the

    latter option.

    Results
    Profiles of Sex-Based Harassment

    Similar to Study 1, we standardized the attorney women’s

    scores on the subscales of the SEQ, including all women

    who had reported at least one experience of an SEQ

    behavior (n = 491). We again performed a k-means cluster

    analysis of these subscales, and again chose a 5-cluster

    solution. Profiles of attorney women’s means on the z-

    scored SEQ appear in Fig. 2.

    Mirroring the profiles from the military sample, the

    largest group consisted of women who reported minimal

    experiences of harassment (Group 1; n = 320). Those who

    disclosed high levels of gender harassment, with almost no

    unwanted sexual attention or sexual coercion, made up the

    second-largest group (Group 2; n = 134). Group 3

    (n = 30) described episodes of unwanted sexual attention,

    in addition to moderate levels gender harassment. Group 4

    (n = 3) and Group 5 (n = 4) were quite small, and dis-

    closed moderate and high levels of all types of harassment

    measured by the SEQ, respectively. To summarize, over

    90% of harassed women fell into one of the two groups

    reporting little or no sexually advancing harassment

    experiences (Group 1 or 2), further supporting Hypothesis

    1. We also identified a group of Nonvictims (n = 338),

    who had responded ‘‘never’’ to all items of the SEQ.

    Demographic information for each of the profile groups

    appears in Table 5. Using chi-square and F tests, we found

    no significant relationships between profile membership

    and race, v2 (5, N = 1317) = 4.24, p = .52; age, F (37,
    1286) = 0.79, p = .81; or years practicing law F (5,

    1333) = 0.98, p = .43.

    Table 4 Descriptive statistics, alpha coefficients, and correlations—Sample 2

    (Attorneys)

    Variables M SD a 1 2 3 4 5

    1. Gender harassment 1.74 2.14 .69 –

    2. Unwanted sexual attention 0.19 0.79 .74 .42** –

    3. Sexual coercion 0.01 0.12 .84 .14** .41** –

    4. Intention to change careers 6.00 2.93 .74 .02 .03 .00 –

    5. Professional relationship satisfaction 12.04 2.24 .76 -.06* -.04 -.02 -.36** –

    6. Job stress 9.17 2.74 .75 .15** .04 .06* .32** -.34**

    Note. Scale-scores were derived by summing responses across all items in each scale for all women in the sample; higher scores reflected greater
    levels of the underlying construct

    ** p \ .01, * p \ .05

    7
    Unlike the military survey in Study 1, the brevity of this subscale

    precluded distinctions between ‘‘sexist’’ and ‘‘crude’’ gender harass-

    ment. Together, the two items assessed ‘‘gender harassment’’ as a

    global phenomenon.

    34 Law Hum Behav (2011) 35:25–39

    123

    Outcomes of Sex-Based Harassment

    Again, for theoretical reasons, the group that experienced

    high gender harassment (without sexual attention or coer-

    cion; Group 2, n = 134) was the focus of our primary

    outcome analysis. To serve as a comparison group of sim-

    ilar size, we randomly selected 150 women from the

    Nonvictims group. We then compared these 150 Nonvic-

    tims to the 134 Gender Harassment victims on the three job-

    related outcomes, using MANCOVA. Racial minority sta-

    tus and years practicing law served as covariates. Again,

    results suggested that there was a significant multivariate

    main effect of gender harassment on the collection of out-

    comes, Wilks’ Lambda = .96, F (3, 238) = 3.00, p \ .05.
    Follow-up univariate analyses (ANCOVAs), reported in

    Table 6, revealed significant effects on job stress and sat-

    isfaction with professional relationships. Compared to their

    non-harassed counterparts, gender-harassed women repor-

    ted significantly higher levels of job stress (d = .34). They

    also described less satisfaction with their relationships with

    federal judges, other attorneys in the federal court, and

    court personnel (d = .32). However, we did not find a

    significant group difference in intention to change careers

    (the means for both groups were similarly low: close to six,

    on a scale that can range from 3 to 15). With the exception

    of this last result, Hypothesis 2 was supported among

    women attorneys.

    To provide additional insight into group differences, we

    again combined Groups 3, 4, and 5 into a Sexual Advance

    Harassment group (n = 37); their outcome means appear in

    Table 6. We compared the outcomes of this group with

    those of the Nonvictims and Gender Harassment Victims

    (using MANCOVA), finding a significant multivariate main

    effect of harassment on outcomes, Wilks’ Lambda = .95, F

    (6, 546) = 2.29, p \ .05. Follow-up Tukey tests indicated
    that the Sexual Advance group differed significantly from

    the Nonvictims group in terms of professional relationship

    satisfaction. The Gender Harassment Victims also reported

    less professional relationship satisfaction, and more job

    stress, than Nonvictims. Gender Harassment Victims did

    not differ significantly from Sexual Advance Victims,

    however, on any outcome. Put differently, we found that

    gender-harassed women attorneys fared just as poorly as

    those who had experienced sexual advance harassment.

    General Discussion

    This article draws attention to the incidence and correlates

    of gender harassment in the workplace. Social science

    -2
    0
    2
    4
    6
    8
    10
    12
    14

    Gender
    Harassment

    Unwanted Sexual
    Attention

    Sexual Coercion

    Z
    -S
    c
    o
    re
    s

    High Victimization (0.8%) –
    Group 5

    Moderate Victimization (0.6%)
    – Group 4

    Gender harassment and
    Unwanted Sexual Attention
    (6.1%) – Group 3

    Gender Harassment (27.3%)
    – Group 2

    Low Victimization (65.2%) –
    Group 1

    Fig. 2 Profiles of harassment
    among women attorneys

    (n = 491)

    Table 5 Descriptive statistics
    for profile groups—Sample 2

    (Attorneys)

    Profile group Non-White Percent Age Years practicing law

    M SD M SD

    Nonvictims (n = 851) 5.2 39.37 8.09 2.23 0.91

    Group 1: Low Victimization (n = 320) 6.7 38.32 7.31 2.21 0.90

    Group 2: Gender Harassment (n = 134) 4.5 39.45 7.36 2.37 0.87

    Group 3: Gender Harassment & Unwanted

    Sexual Attention (n = 30)
    6.7 37.63 6.13 2.23 0.77

    Group 4: Moderate Victimization (n = 3) 0.0 42.50 0.71 2.67 0.58

    Group 5: High Victimization (all types) (n = 4) 25.0 35.00 2.31 1.75 0.50

    Law Hum Behav (2011) 35:25–39 35

    123

    research has often analyzed sex-based harassment as a

    global phenomenon, failing to distinguish among the dif-

    ferent facets of behavior; this practice may have obscured

    the experiences of many harassed women, especially those

    working in male-dominated fields. At the same time, many

    federal judges have evaluated potentially harassing conduct

    through a (hetero)sexualized lens, in which they privilege a

    ‘‘top-down, male-female sexual come-on image of

    harassment’’ (Schultz, 2006, p. 26). This ‘‘sexual model of

    sexual harassment’’ does not provide an explanation for

    gender harassment that is devoid of sexual interest, which

    we found to be the norm in women’s experiences of

    harassment in traditionally masculine domains.

    Key Findings

    The first goal of this article was to investigate the preva-

    lence of different dimensions of sexually harassing

    conduct. Consistent with our hypothesis, gender harass-

    ment in the absence of unwanted sexual attention or sexual

    coercion was the most common manifestation of harass-

    ment faced by women in the military and the law

    (employment contexts which, importantly, were once the

    exclusive province of men). In fact, in both settings, 9 out

    of every 10 victims had experienced primarily gender

    harassment, with virtually no unwanted sexual overtures.

    Taken together, our empirical results support the legal

    theory that ‘‘much of the time, harassment assumes a form

    that has little or nothing to do with sexuality but everything

    to do with gender’’ (Schultz, 1998, p. 1687). This conduct

    is not about misguided attempts to draw women into sexual

    relationships; quite the contrary, it rejects women and

    attempts to drive them out of jobs where they are seen to

    have no place. One could argue that, in these instances,

    ‘‘sexual harassment is used both to police and discipline the

    gender outlaw: the woman who dares to do a man’s job is

    made to pay’’ (Franke, 1997, p. 764). Had we collapsed

    across the subtypes of harassing behavior, as many psy-

    chologists do, this striking pattern of results would not have

    surfaced.

    The second goal of this article was to understand the

    correlates of gender harassment for working women. When

    comparing victims of gender harassment to women who

    reported no harassment experiences, we found that ‘‘just’’

    gender harassment was associated with multiple negative

    outcomes. Specifically, in the military context, gender-

    harassed women reported lower psychological well-being,

    job performance, job commitment, and satisfaction with

    their employment and health; they also described more

    thoughts and intentions of leaving their jobs. These results

    remained significant even after controlling for the women’s

    race, rank, and service branch. Among attorneys, gender-

    harassed women (compared to nonharassed women)

    reported lower satisfaction with professional relationships

    and higher job stress, above and beyond the effects of race

    and job tenure. Thus, experiences of gender harassment

    alone were associated with negative personal and profes-

    sional outcomes in two very different contexts of work.

    Implications for Sexual Harassment Jurisprudence

    This research has important legal implications. Although

    popular wisdom might suggest that the legal definition of

    sexual harassment is fixed, in actuality the legal under-

    standing changes as courts interpret and refine precedent.

    Our research underscores the need to broaden legal and

    scientific conceptualizations of sexual harassment, so that

    gender harassment can be recognized as a harmful and

    objectionable condition of employment, even when not

    paired with unwanted sexual attention. Title VII of the

    Civil Rights Act of 1964 says nothing about sexual

    behavior. Definitions that limit sex-based harassment to

    unwanted advances emerged over time as the courts

    revised their interpretations of Title VII. Our results sug-

    gest that further revision is in order, to prohibit not just

    sexually predatory conduct, but also behavior that creates a

    hostile work environment for members of one sex but

    contains no sexual advance—that is, gender harassment. As

    we have shown, gender harassment does not simply pro-

    vide a backdrop for other kinds of harassment; it is the

    modal form of sex-based harassment faced by women at

    work (at least in male-dominated domains). Moreover, it

    alters the terms of employment for targeted women, being

    associated with a variety of negative professional

    outcomes.

    Table 6 ANCOVAs for job-related outcomes—Sample 2 (Attorneys)

    Outcome measured Nonvictims Gender Harassment
    Victims
    Sexual Advance
    Harassment Victims
    df F p
    Mean (SD) 95% CI Mean (SD) 95% CI Mean (SD) 95% CI

    1. Intention to change careers 5.81 (3.01) 5.32, 6.31 5.95 (2.93) 5.45, 6.46 6.51 (3.25) 5.43, 7.60 2, 307 0.98 .452

    2. Professional relationship satisfaction 12.51 (2.14) 12.15, 12.86 11.81 (2.21) 11.43, 12.18 11.38 (2.97) 10.39, 12.37 2, 308 5.25 .006

    3. Job stress 9.04 (2.84) 8.53, 9.55 10.01 (2.82) 9.51, 10.50 9.76 (3.67) 8.48, 11.04 2, 277 3.61 .032

    36 Law Hum Behav (2011) 35:25–39

    123

    Our outcome results suggest that harassment exclusively

    consisting of gender-related hostility has adverse work-

    related correlates. That is, the more that women experi-

    enced gender harassment, the less satisfied they were with

    their jobs and colleagues, the more they experienced stress

    on the job, and the more they suffered health problems that

    detracted from their job performance. Moreover, these

    results were not trivial in magnitude, being associated with

    large effect sizes in some cases (particularly for coworker

    satisfaction and psychological well-being). Findings such

    as these could be relevant to legal claims of hostile envi-

    ronment sexual harassment.

    As noted at the outset of this article, in Harris v Forklift

    Systems, Inc. (1993) the Supreme Court stated that ‘‘all the

    circumstances’’ must be considered when determining

    whether an environment is ‘‘hostile’’ or ‘‘abusive,’’ in

    violation of Title VII. The Court went on to say that these

    circumstances may include a number of factors, including

    whether the discriminatory conduct ‘‘unreasonably inter-

    feres with an employee’s work performance’’ Harris v

    Forklift Systems, Inc. (1993, p. 23). In the current study, we

    documented that gender harassment on its own is linked

    with a variety of adverse work outcomes, including but not

    limited to performance decline. These outcomes do not

    necessarily reflect traumatization or incapacitation of the

    victim, but this is not a requirement of Title VII: ‘‘…Title
    VII comes into play before the harassing conduct leads to a

    nervous breakdown. A discriminatorily abusive work

    environment, even one that does not seriously affect

    employees’ psychological well-being, can and often will

    detract from employees’ job performance, discourage

    employees from remaining on the job, or keep them from

    advancing in their careers’’ (Harris v Forklift Systems, Inc.,

    1993, p. 21). Although we cannot draw definitive causal

    conclusions from our correlational findings, our results are

    consistent with these sorts of effects. They support the

    possibility that ‘‘just’’ gender harassment can create a

    hostile environment that disadvantages women.

    Limitations

    As with any research, our studies have their limitations. All

    results were based on cross-sectional, correlational data,

    precluding strong temporal or causal inferences. That said,

    longitudinal studies of sexual harassment (e.g., Glomb,

    Munson, Hulin, Berman, & Drasgow, 1999; Sims et al.,

    2005) provide compelling evidence that our personal and

    professional outcomes follow, rather than precede,

    harassment experiences. These data were self-reported;

    because of this, common method variance or response set

    could potentially explain some of the significant findings.

    Surveys were designed to minimize some of these prob-

    lems: questions about mental health, physical health, and

    job attitudes were asked prior to and independently of the

    SEQ, so that responses about harassment did not bias

    reports of health and attitudes. Also, we were only able to

    use proxies for job and career turnover, with measures of

    turnover intentions rather than actual turnover rates.

    However, past research tells us that one of the best pre-

    dictors of actual turnover is thoughts of turnover (e.g.,

    Griffeth, Hom, & Gaertner, 2000). Finally, while we did

    cross-validate results across two large samples that differed

    by ethnicity and socio-economic status, both samples came

    from male-dominated organizations. Gender parity has

    increased in both industries, but as of 2008, only 34% of

    lawyers were women (U.S. Department of Labor, 2009),

    and as of September 2009, only 14% of active-duty mili-

    tary personnel were women (Department of Defense,

    2009).

    We should also emphasize that our data combine the

    experiences of hundreds of women, and just because gen-

    der harassment correlates with negative outcomes in these

    aggregate data does not mean that this behavior has neg-

    ative outcomes for every individual victim. We found that

    this is true on average. Whether it is true for any individual

    woman is a determination that must be made on a case-by-

    case basis. Our point is simply that courts and social sci-

    entists should not automatically assume that ‘‘just gender

    harassment’’ is, by definition, too trivial to create an abu-

    sive work environment.

    Future Directions

    Social scientists continue to focus on sexual ‘‘come-on’’

    forms of sexual harassment (e.g., de Haas, Timmerman, &

    Höing, 2009; Woodzicka & LaFrance, 2005). When sur-

    veys do include questions about gender harassment, during

    the analysis of data these questions are often combined

    with questions about unwanted sexual advances (e.g.,

    Fitzgerald, Drasgow et al., 1997; Sims et al., 2005). This

    happens even though there are major qualitative differ-

    ences across the experiences; for example, being sexually

    propositioned on one occasion is not the same as being

    targeted with demeaning anti-female remarks on a daily

    basis. Based on the current study, we recommend that more

    research parse out experiences of gender harassment from

    unwanted sexual attention/coercion, which will give rise to

    new avenues of inquiry. For example, proponents of the-

    ories as to why people harass others have generally looked

    for one unifying explanation (e.g., Bargh, Raymond, Pryor,

    & Strack, 1995; Berdahl, 2007b). It remains entirely pos-

    sible that different goals motivate the different subtypes of

    sex-based harassment.

    Regarding construct labels, we second Berdahl’s

    (2007b) recommendation that the term ‘‘sex-based harass-

    ment’’ be used in lieu of ‘‘sexual harassment.’’ Research on

    Law Hum Behav (2011) 35:25–39 37

    123

    lay perceptions suggests that the latter term conjures up

    narrow notions of unwanted sexual advances; it fails to

    include gender harassment in the minds of many (e.g.,

    Fitzgerald & Ormerod, 1991; Loredo et al., 1995; Tang

    et al., 1995). The term ‘‘sex-based harassment’’ is broader,

    calling attention to both categories of behavior. It is also

    closer to the original language of Title VII, which pro-

    hibited harassment ‘‘based on sex.’’

    The current study focused on two male-dominated pro-

    fessions. Researchers have not yet determined how ‘‘just

    gender harassment’’ operates in gender-balanced and

    female-dominated industries. We would speculate that the

    behavior might be less common in more female-integrated

    contexts, where women are not perceived as ‘‘encroach-

    ing’’ on ‘‘men’s territory.’’ In those settings, anti-female

    hostility might also be less tolerated and more penalized,

    and thus experienced by victims as less threatening. These

    and other possibilities await future research.

    In closing, we emphasize the need for scholars of sex-

    based harassment, both in psychology and law, to continue

    the interdisciplinary exchange of ideas. Social scientists

    and legal theorists often struggle to converse, but consid-

    erable efforts have been made to bridge the disciplinary

    gap when it comes to this topic (for examples, see the

    special issue on ‘‘sexual harassment’’ in Psychology,

    Public Policy, and Law, 1999, and the special issue on

    ‘‘psychology, law, and the workplace’’ in Law and Human

    Behavior, 2004). The arguments of prominent legal

    scholars inspired the current psychological research. We

    hope that, in turn, our results can inform further evolution

    in legal thinking about harassment based on sex and

    gender.

    Acknowledgments We are grateful to Anna Kirkland, Abby
    Stewart, and members of our research lab at the University of

    Michigan for their valuable feedback on this research. Thanks also to

    the following individuals for their contributions to Study 2: Louise F.

    Fitzgerald, Leslie V. Freeman, Vicki J. Magley, Kimberly A. Lon-

    sway, Regina Day Langhout, Jill Hunter-Williams. This article is

    based on the master’s thesis of the first author, who presented parts of

    it in July 2008 at the Annual Meeting of the International Society for

    Political Psychology in Paris, France.

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    • c.10979_2010_Article_9241
    • Gender Harassment: Broadening Our Understanding of Sex-Based Harassment at Work
      Abstract
      Central Constructs
      Legal Perspectives on Sexual Harassment
      Psychological Research on Sexual Harassment
      If It’s ‘‘Just’’ Gender Harassment, Why Should We Care?
      Hypotheses
      Study 1: The Military Survey
      Participants and Procedure
      Measures
      Sex-Based Harassment
      Psychological Well-Being
      Performance Decline Due to Poor Emotional Health
      Performance Decline Due to Poor Physical Health
      General Health
      Work Attitudes
      Turnover Intentions
      Control Variables

      Results
      Profiles of Sex-Based Harassment
      Outcomes of Sex-Based Harassment
      Study 2: The Attorney Survey
      Participants and Procedure
      Measures
      Sex-Based Harassment
      Job-Related Outcomes
      Control Variables

      Results
      Profiles of Sex-Based Harassment
      Outcomes of Sex-Based Harassment
      General Discussion
      Key Findings
      Implications for Sexual Harassment Jurisprudence
      Limitations
      Future Directions
      Acknowledgments
      References

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