The growing tension between Rule 23 class actions and hostile environment sexual harassment claims

The law of hostile environment sexual harassment has seen many developments in recent years, due to both the amendment of Title VII of the Civil Right s Act and several significant Supreme Court decisions. These changes have o nly intensified the dilemma courts must face when confronted with hostile e nvironment harassment in the class action context. The necessary individual ized inquiries associated with today's hostile environment claims do not le nd Themselves to resolution through a class action more easily or quickly t han through separate lawsuits.