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When a woman harasses a female coworker out of competitiveness or jealousy, can such harassment be sex-based? Can it give rise to a sexual harassment hostile work environment claim? This Note argues that the answer to both questions is yes because, in many instances of female-onfemale harassment, women in the workplace are undermining each other as women. Moreover, female-on-female harassment is often created by sex segregation and discrimination in the workplace, and falls squarely under the coverage of Title VII of the Civil Rights Act of 1964. Title VII prohibits an employer from discriminating against employees based on race, color, religion, sex, or national origin. It states, in relevant part:

"Hostility to the Presence of Women": Why Women Undermine Each Other in the Workplace and the Consequences for Title VII