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 Rights Act and several significant Supreme Court decisions. These changes have only intensified the dilemma courts must face when confronted with hostile environment harassment in the class action context. The necessary individualized inquiries associated with today's hostile environment claims do not lend Themselves to resolution through a class action more easily or quickly than through separate lawsuits.