id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
cjgl-2496	Lawton, Anne	Operating in an Empirical Vacuum: The Ellerth and Faragher Affirmative Defense	2004	77	.pdf	application/pdf	38786	1396	47	Nov. 13, 2001) (affirming district court order granting summary judgment to employer, rejecting plaintiffs argument that her employer had not satisfied prong one because it had not shown that her harasser had received sexual harassment training by concluding that 'distribution of an anti-harassment policy provides compelling proof that the company exercised reasonable care in preventing and promptly correcting sexual harassment' (quoting Barrett v. Applied Radiant Energy Corp., 240 F.3d 262, 266 (4th Cir. 2001)); Gawley v. Ind. Univ., 276 F.3d 301, 311-12 (7th Cir. 2001) (affirming district court order granting summary judgment on plaintiffs sexual harassment claim, concluding that plaintiff had no evidence that the [employer] failed to exercise reasonable care in preventing and correcting the harassing behavior because the employer had a system in place for employees to report sexual harassment and, once reported, the employer took action and the harassment stopped); Hill v. Am. 2d 999, 1007 (D.S.D. 2001) (granting employer's motion for summary judgment on plaintiffs sexual harassment claim and noting, in dicta, that employer could prevail on the affirmative defense, in part, because the employer had in place policies and procedures for handling sexual harassment [and]	cache/cjgl-2496.pdf	txt/cjgl-2496.txt