vances, requests for sexual favors, and other verbal or physical conduct of a sexual nature constitute sexual harassment when this conduct explicitly or implicitly affects an individual's employment, unreasonably interferes with an individual's work performance, or creates an intimidating, hostile, or offensive work environment. In Harris v. Forklift Sys., Inc., No. 92-1168 slip op. (Nov. 9, 1993), the Supreme Court considered whether a plaintiff was required to prove psychological injury in order to prevail on a cause of action alleging hostile environment sexual harassment under Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. §§ 2000e et seq. A unanimous Court held that if a workplace is permeated with behavior that is severe or pervasive enough to create a discriminatorily hostile or abusive working environment, Title VII is violated regardless of whether the plaintiff suffered psychological harm. The Court's decision reaffirms Meritor Savings Bank v. Vinson, 477 U.S. 57, 40 EPD 36,159 (1986), and is consistent with existing Commission policy on hostile environment harassment. Consequently, the Commission will continue to conduct investigations in hostile environment harassment cases in the same manner as it has previously. In Europe, under the Sex Discrimination Act it is unlawful for employers and other organizations to treat women or men less favorably because of their sex in the area of employment. Under the Sex Discrimination Act if your health has suffered and you have medical reports that show that this is as a result of the treatment you have received, you may also have a personal injury claim. If you decide to take legal action, you should make it clear on your tribunal claim that you are also claiming damages for the personal injury you have suffered as a result of the discrimination by using "breach of the statutory tort of discrimination." With this in consideration, I prefer the...