Screaming and yelling by men at work may now be sex-based discrimination if women at work find the behavior more intimidating than men do. On September 2, 2005, in E.E.O.C. v. National Education Association, (No. 04-35029), the Ninth Circuit Court of Appeals ruled that the “reasonable woman” standard applies to workplace abusive conduct, even if there is no sexual content to the behavior. This decision significantly expands the types of behaviors that may furnish a basis for a claim of discrimination. Three women working for a labor union, the National Education Association, sued for gender discrimination claiming that the NEA...