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| SEXUAL HARASSMENT MUST BE IN EMPLOYEE'S ORBIT |
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| A jury found that a Deputy Superintendent for the New York City subway suffered sexual harassment upon hearing that two female cleaners were being harassed, including unwelcome touching and propositions. After the women complained, the Deputy Superintendent experienced a major depressive disorder when her attempt to help the women failed. The Second Circuit reversed the jury verdict finding that the alleged harassment was out of plaintiff's sight and "regular orbit;" there was no evidence that her working environment was hostile or that the harassment of others adversely affected the terms and conditions of her own employment. |
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| (Leibovitz v. New York City Transit Auth.) |
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