Hastings Women’s Law Journal


Sarah L. Ream


Sexual harassment in the workplace, a form of sex discrimination, has received substantial legislative and judicial attention in the past several decades. Courts have recognized that harassment may arise from supervisor or co-worker conduct. Increasingly, courts are also acknowledging harassment by third-parties, such as independent contractors or customers. This note examines the law of such "third-party sexual harassment" with regard to harassment perpetrated by customers. Particular attention is given to the implications of charges filed against a major super market chain alleging harassment by customers due to the implementation of a customer service policy.