In the case of Roberts v. Mike’s Trucking, Ltd., Teresa Roberts worked for Mikes’ Trucking, Ltd., in Columbus, Ohio. Her supervisor was Mike’s owner,Mike Culbertson. According to Roberts, Culbertson called her his “sexretary” and constantly talked about his sex life. He often asked her if she wanted to sit on “Big Daddy’s” lap, rubbed his crotch against her, trapped her at the door and asked for hugs or kisses, and asked if she needed help in the restroom. Roberts asked him to stop the behavior, to no avail. She became insecure and less productive, and began to suffer anxiety attacks and high blood pressure. Roberts filed a suit in an Ohio state court against Mike’s, alleging a hostile work environment through sexual harassment. From a judgment in Roberts’s favor, Mike’s appealed.
A state intermediate appellate court affirmed. Other female employees corroborated Roberts’s account. “There was sufficient and substantial evidence * * * that a reasonable person would find Culbertson’s conduct created a hostile environment and Roberts found the conduct to be sufficiently severe or pervasive to affect her employment.”
Does conduct need to be both severe and pervasive to constitute a hostile or abusive work environment under Title VII of the Civil Rights Act of 1964? Give and discuss reasons for your answer.
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