id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
inlawrev-3075	Michelsen, Jan	A Class Act: Forces of Increased Awareness, Expanded Remedies, and Procedural Strategy Converge to Combat Hostile Workplace Environments	1994	40	.pdf	application/pdf	20357	1149	58	Such an approach, to isolate and then deny certification of the harassment claim, has been used previously to prevent sexual harassment class actions. Sheehan v. Purolator, Inc., 839 F.2d 99 (2d Cir. 1988); Holden v. Burlington N., Inc., 665 F. Supp. 1398 (D. Minn. 1987). 1994 SEXUAL HARASSMENT CLASS ACTIONS 621 Even though sexual harassment class actions are clearly procedurally appropriate, one could posit three reasons that the first class certified for a claim of hostile environment harassment as sex discrimination did not appear until as late as 1991. ^'^	cache/inlawrev-3075.pdf	txt/inlawrev-3075.txt