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Sexual Harassment, Content Neutrality, and the First Amendment Dog That Didn't Bark

In Harris v Forklift,1 one of the first wo cases handed down during the 1993 Term, the Supreme Court decided with great speed and astonishing unanimity that an employee need not show serious psychological or other injury in order to prove sexual harassment prohibited by Title VII. Somewhat surprisingly, in light of increased publicity about collisions between speech and equality interests and despite briefing of free speech issues by both sides, the Court's opinion in Harris made no reference to the First Amendment. Less than two years before Harris, in R.A. V. v St. Paul,2 the Supreme Court invalidated a municipal ordinance that forbade the utterance of "fighting words" likely to "arouse anger, alarm, or resentment in others on the basis of race, color, creed, religion, or gender"' on First Amendment grounds. Title VII forbids harassment on similar bases. Moreover, the "hostile environment" cause of action involved in Harris frequently imposes liability based on speech and expressive conduct. Some observers therefore thought