4440 REVIEW DENIED An employer is strictly liable for sexual harassment committed by an employee's supervisor unless it occurred during a completely private relationship unconnected with the employment; an employer's failure to provide employees with information about their rights to be free of sexual harassment as required by the Fair Employment and Housing Act (FEHA) can result in liability for failure to take reasonable steps to prevent sexual harassment; in common law tort claims a private employer is not vicariously liable for sexual misconduct committed by an employee against a subordinate.


MYERS v TRENDWEST (Groping Supervisor) 148 CA4 1403 [See: GovC 12940 etseq; CivC 3294; State Dept / Hlth Svcs v Superior Court 31 C4 1026, T/AT 12/03; Medix v Superior Court 97 CA4 109, P/AT 5/02; Mary M v. City of LA 54 C3 202; Farmers v County 11 C4 992, T/AT 1/96]