Godfrey v. Princeton Theological Seminary

In Lehmann v. Toys ‘R’ Us, Inc., 132 N.J. 587, 626 A.2d 445 (1993), Justice Garibaldi, writing for this Court, delineated the standards of proof that are necessary in order to bring a discrimination claim premised on acts of sexual harassment. To demonstrate a discriminatory hostile environment caused by sexual harassment, a plaintiff must show that “the complained-of conduct (1) would not have occurred but for the employee’s gender; and it was (2) severe or pervasive enough to make a (3) reasonable woman believe that (4) the conditions of employment are altered and the working environment is…