Task: Text Completion
Input (English): has never adopted the Ellerth/Faragher model for vicarious liability of an employer for [ ] harassment by a supervisor,” instead relying on the “known or should have known” standard for assessing liability. Stricker v. Cessford Construction Co., 179 F.Supp.2d 987, 1014 (N.D.Iowa 2001); see McElroy v. State, 637 N.W.2d 488, 499 (Iowa 2001) (using federal case law to flesh out the distinction between quid pro quo harassment and sexually hostile work environment claims under the ICRA); Greenland v. Fairtron Corp., 500 N.W.2d 36, 38 (Iowa 1993) (analyzing propriety of a sexually hostile work environment claim under the ICRA using the same factors as employed by federal courts in analyzing comparable claims under Title VII); Lynch v. City of Des Moines, 454 N.W.2d 827, 833-34 (Iowa 1990) (<HOLDING>); Chauffeurs, Teamsters and Helpers, Local 
 Holding statements: (A) recognizing a hostile work environment claim under section 1983 (B) recognizing that the elements of title vii sexually hostile work environment claims apply to icra sexually hostile work environment claims (C) holding that the elements of a hostile environment claim under title vii equally apply under title ix (D) recognizing hostile work environment discrimination in ada context (E) holding that a viable hostile work environment claim requires an environment that a reasonable person would find hostile or abusive
Output (English): (B)