Some states and districts have held employers strictly liable for supervisor harassment. Here, the harassment was alleged to have occurred in private, and the victim never reported it. The victim admitted she had read the employer policy on harassment, had received a pamphlet the employer had distributed, and had attended a company training program on the subject. Yet she never took advantage of the procedure to file a complaint. The court held that given the employer's proactive stance in preventing harassment, the employer had not been negligent in its handling of the matter, and therefore was not liable.
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