ADVANTAGES

InHighlander and also in Rabidue v. Osceola RefiningCo., 805 F.2d 611, 41 EPD ¶ 36,643 (6th Cir.1986), cert. denied, 107 S. Ct. 1983, 42 EPD ¶ 36,984 (1987),the Sixth Circuit required an additional showing that the plaintiffsuffered some degree of psychological injury. Highlander,805 F.2d at 650; Rabidue, 805 F.2d at 620. However, it isthe Commission's position that it is sufficient for the chargingparty to show that the harassment was unwelcome and that it wouldhave substantially affected the work environment of a reasonableperson.

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