A recent decision handed down by the Federal Appeals Court in Chicago has further refined the parameters of a sexual harassment claim under Title VII.  Judge Posner authored the decision which concluded that "Title VII is not a code of civility" and that an employee in the American workplace cannot recover damages simply because one is offended by a co-employee's conduct or language at work.  Rather, in order to rise to the level of a hostile work environment actionable under Title VII, an individual employee must show that she (or he) was the "target" of the offensive conduct or language.  Thus, the mere fact that an employee believes another employee's conduct or language is offensive in general or offensive to another would not, in most cases, give rise to a claim.

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