This Comment discusses the impact of the #MeToo movement on the Third Circuit’s reasoning in Minarsky and sets forth the legal and cultural implications of the decision. Section II contextualizes the anti-sexual harassment movement before the #MeToo movement in the United States and how the law came to reflect that movement through landmark Supreme Court cases. It then discusses how the Third Circuit has interpreted those cases in the wake of the #MeToo movement. Section III puts forth various studies and statistics on sexual harassment and discusses how Minarsky reflects those findings. Further, it discusses the legal and cultural implications for employers in light of the Third Circuit’s precedential decision.
Catherine Houseman is a J.D. Candidate, Temple University Beasley School of Law, 2020.