This note discusses applicable principles and law in sexual harassment cases, including Title VII, Equal Employment Opportunity Commission Guidelines, agency principles, and case law that illustrate two primary approaches taken by the courts in determining the standard for employer liability. This section also discusses relevant portions of the first Supreme Court case to address sexual harassment under Title VII. Section III discusses the facts that gave rise to EIlerth\u27s sexual harassment claims. Section IV discusses the procedural history of Ellerth\u27s case, including the district court\u27s decision, the decision of the Seventh Circuit panel that heard Ellerth\u27s appeal and the en banc decision of the Seventh Circuit. Section V discusses the Supreme Court\u27s opinion in Ellerth v. Burlington Industries in the context of sexual harassment law under Title VII. Section VI offers a critique of the Supreme Court\u27s analysis, asserting that it is inconsistent with agency principles. Finally, Section VII concludes that a brightline standard of employer liability, based on agency principles, is necessary in Title VII sexual harassment cases
