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  Jensen v. Potter, No. 04-4078 (3d Cir. Jan. 31, 2006) Littler Mendelson, P.C. - February 10, 2006 Employers who monitor their potential liability for workplace harassment should add retaliatory harassment to their growing unlawful harassment checklist, if they have not already done so. In a recent decision, the United States Court of Appeals for the Third Circuit held that retaliatory harassment is an adverse employment action under Title VII of the Civil Rights Act of 1964. Jensen v. Potter, No. 04-4078 (3d Cir. Jan. 31, 2006). The decision was authored by Judge Samuel Alito on the same day he was sworn in as an Associate Justice of the Supreme Court of the United States.
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