Sexual Harrassment without the Sex?

law.com reports that the 9th Circuit Court of Appeals may have taken the sex out of sexual harrassment. " The opinion, in a case originating at an Alaska teachers union, said that Thomas Harvey, a manager accused of 'shouting, screaming, foul language, invading employees' personal space and [making] threatening gestures" may be sued for gender-based discrimination under Title VII of the Civil Rights Act of 1964, even though his acts were not overtly motivated by the victims' gender." This could be scary for some law firm environments! Check it out - this may be a good time for that anger-management class you've wanted to send some of your lawyers to. Christopher v. National Education Association, 05 C.D.O.S. 7999.