id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
inlawrev-3302	Ogden, Patricia L.	Survey of Labor and Employment Law Developments for Indiana Practitioners	1998	22	.pdf	application/pdf	8941	588	61	Judge Flaum concurred that negligence is the appropriate standard for employer liability, in part because of the difficulties employers would face in defining actionable behavior and communicating a consistent message to employees.' ' • Judge Cudahy principally concurred with Judge Flaum 's approach, emphasizing that a heightened standard of negligence is appropriate in supervisory hostile environment harassment cases. Although the panel was unable to forge a clear-cut majority, the majority reached consensus that negligence is the proper standard for employer liability in hostile environment sexual harassment claims when the alleged harasser is the employee's supervisor.^^	cache/inlawrev-3302.pdf	txt/inlawrev-3302.txt