The EEOC filed a lawsuit against NEA-Alaska, a labor union that represents teachers and other public school employees, alleging that the union had created a sex-based hostile work environment for three female employees. The female employees testified that repeated and severe instances had occurred, during which Thomas Harvey, the union’s assistant executive director, shouted, used foul language, invaded their space (including an incident when he grabbed a female employee from behind), and made threatening physical gestures. NEA-Alaska responded that Harvey treated male and female employees the same way and that there was no evidence that Harvey made sexual overtures or lewd comments that he referred to women in gender-specific terms, or that he imposed gender-specific requirements on the female employees. In other words, Harvey treated male and female employees the same way. How should NEA-Alaska respond? Who should prevail? If you were Harvey’s supervisor, what would you do? [Christopher v. National Education Association, 422 F.3d 840 (9th Cir. 2005).]