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Sexual harassment is a recognized form of sexual discrimination actionable under Title VII of the Civil Rights Act of 1964. Although this statement of the law is accurate, it is more realistic to say that some sexual harassment is actionable under Title VII. The modifier "some" is made necessary by a basic problem plaguing courts-there is no consensus on exactly what types of behavior constitute sexual harassment.2 As the courts have struggled to develop sexual harassment law, one distinct theme has emerged: Men and women often have very different perceptions of what is appropriate sexual conduct in the workplace and, therefore, of what conduct is offensive or harassing. In 1980, the Equal Employment Opportunity Commission (EEOC) established guidelines defining sexual harassment: "Unwelcome sexual [conduct] constitute[s] sexual harassment when ... such conduct has the purpose or effect of unreasonably interfering

Is There a Place for a Reasonable Woman in the Law? A Discussion of Recent Developments in Hostile Environment Sexual Harassment