HOSTILE ENVIRONMENT SEXUAL HARASSMENT CLAIMS - WHEN ONCE IS ENOUGH

The Supreme Judicial Court of Maine recently held, in Nadeau v. Rainbo w Rugs, Inc., that a single incident of sexual harassment may be suffi cient to create a hostile work environment. The author concludes, base d on an analysis of the two leading United States Supreme Court decisi ons in this area of the law, that the court's conclusion in Nadeau is correct. Additionally, the author discusses the Nadeau court's observa tion that the severity of harassing conduct may vary inversely with it s pervasiveness, and suggests this standard as a useful tool in analyz ing whether motions for summary judgment may, or should, be granted in single-incident sexual harassment cases.