In "quid pro quo" cases, a single sexual advance can be considered actionable harassment.

However, in "hostile environment" cases, generally, a single incident does not create a "hostile environment." A hostile environment claim usually requires a showing of a pattern of offensive conduct but the more egregious the conduct, the less the need to show a repetitive series of incidents.

In a unanimous decision of the U.S. Supreme Court in April, 2001, a supervisor's isolated single crude remark was not enough to trigger a sexual harassment case under the federal civil rights law (Clark County School District v. Breeden). The justices stated that, based on the reasoning in previous cases, sexual harassment refers to a pattern of "severe or pervasive" abuse; the supervisor's one offhand, sexual remark was not the type of behavior that supported a sexual harassment claim, though the employee might think it was unlawful harassment.

(Reviewed 9-08)