Here's how the United States Court of Appeals for the Fourth Circuit — hardly a bastion of liberalism — recently summarized it: Similar to the reasoning we set forth for employer liability for co-worker harassment, “an employer cannot avoid Title VII liability for [third-party] harassment by adopting a ‘see no evil, hear no evil’ strategy.' “ Ocheltree v. [read post]

Gresham, 861 F.3d 143, 157 (5th Cir. 2017) (quoting Waltman v. [read post]