If You Grab the Honey, You Better have the Money: An In-Depth Analysis of Individual Supervisor Liability for Workplace Sexual Harassment‪.‬

Meet Jane Doe. Jane is employed as a controller by a small corporation. She is the only woman in an eight-member finance department. Jane works directly for the company's chief financial officer ("CFO"). The CFO has been with the company for some time and manages it with an "old boys' club" mentality. The men in the finance department frequently make lewd jokes, obscene gestures, and offensive comments toward Jane. Not only is this behavior tolerated, but the CFO himself frequently engages in the unwelcome, sexually charged conduct. As a result, Jane, the only woman in the department, feels extremely threatened. After following the appropriate procedures set forth in the company's employee handbook, Jane concludes that nothing seems to have changed. Jane still feels threatened and particularly helpless, as nothing has been done to help alleviate her problems. Jane has filed a claim with the Equal Employment Opportunity Commission and wants to bring a lawsuit against the company. She also desires to bring a suit against the company's CFO in his individual capacity, which would provide her with a fuller sense of vindication. Unfortunately for Jane, her latter cause of action will likely not be recognized in either federal or state court) INTRODUCTION