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Plaintiff, Blakey, became the first female captain to fly an Airbus or A300, qualifying in 1989.
Shortly after her appointment, she complained of conduct and comments directed at her, including pornographic photos and vulgar gender-based comments about her that appeared in the workplace.
refers to the intentional sending of erotic, pornographic, lewd, and lascivious images and digital recordings by a harasser to specific or potential victims.
Graphic harassment often occurs via email, instant messaging, redirected/automatic linking, and pop-ups.
Today, employers need to be vigilant not only to what is said and done in the physical office, but what is being said and done in the virtual office as well.
During litigation, Blakey's co-workers continued to make harassing, gender-based messages aimed at her, which were posted on a company website.
This pressure is often achieved by the use of explicit threats of harm directed towards the victim or relatives and friends of the victim.
The emergence of Internet mediums as the most common method of communication has introduced new elements into combating sexual harassment in the workplace.
Such offensive messages include gender-humiliating comments, rape threats, and sexual remarks which are unwelcome, and are neither invited nor consensual.
Verbal harassment can be either passive or active depending on whether the harasser targets a specific victim (active) or targets potential receivers (passive).
The Court noted that the conduct at issue arose out of employee relationships and was therefore relevant, regardless of where the harassment occurred.