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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

§ 3604

Citation
§ 3604
Parent Document
Rita Fox v. Lucille F. Gaines (2021)
Effective Date
2021-07-16

Full Text

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          A defendant creates a hostile housing environment by subjecting the plaintiff “to
unwelcome sexual harassment” that was “sufficiently severe or pervasive so as to interfere with
or deprive [the plaintiff] of her right to use or enjoy her home.” Quigley v. Winter, 598 F.3d 938,
946–47 (8th Cir. 2010). Quid pro quo sexual harassment occurs when housing benefits are
explicitly or implicitly conditioned on sexual favors. Id. at 947.