In the Matter of Dwayne M. Brown, 703 N.E.2d 1041 (1998)
Six female employees made allegations that an elected clerk had sexually harassed them. The clerk attempted to argue that his actions toward the employees did not meet the standard for “13” as defined by the EEOC. The Court found that it did not need to rely on a federal agency’s definition to “find that the respondent’s creation and perpetuation of a work environment infected with inappropriate and unwelcome sexual advances violated Prof. Cond. R.