n the issue of sexual harassment.4
In the year following Professor Anita Hill's allegations against Supreme Court Justice nominee Clarence Thomas, sexual harassment complaints in America rose by 45 percent.5 Additionally, the Equal Employment Opportunity Commission reported a whopping 9,953 harassment complaints by the end of 1992, which represented an increase of 2,546 claims from the prior year, which ended immediately before the Hill-Thomas hearings. Also, in the six months prior to March 31, 1992, state and federal employment practice agencies reported an increase of more than 1,600 sexual harassment complaints.6 Thus, the Hill-Thomas hearings had a significant impact on women' s attitudes toward sexual harassment. Those hearings provided many American women with new information about harassment and also gave many women enough courage to finally speak out about the incidents of harassment which they were experiencing in the work environment.7 The Hill-Thomas Senate hearings directly caused the surge of sexual harassment grievances which were reported since they were aired on national television.8
The term "sexual harassment" was coined by Lin Farley in 1975.9 Farley was a professor at Cornell University when she invented the phrase, and she used it repeatedly while teaching a course called "Women at Work" during the 1970s.10 Years after Farley first began using the term, sexual harassment was legally defined as any on-the-job sexual advance or conduct which is either unwelcome or creates an intimidating, hostile or offensive working environment.11 Others have defined sexual harassment more simply. Specifically, a more simple definition of sexual harassment encompasses "any offensive conduct related to an employee's gender that a reasonable woman or man should not have to endure."12
Nonetheless, both of the foregoing definitions of sexual harassment are broad and attempt to cover the entire spectrum of sexually harassi...