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The Court stated that an employer is liable for hostile work environment harassment by employees who are not supervisors if the employer was negligent in failing to prevent harassment from taking place.

In assessing such negligence, the Court explained, the nature and degree of authority wielded by the harasser is an important factor to be considered in determining whether the employer was negligent. 2275 (1998), the Supreme Court made clear that employers are subject to vicarious liability for unlawful harassment by supervisors.

Also relevant is [e]vidence that an employer did not monitor the workplace, failed to respond to complaints, failed to provide a system for registering complaints, or effectively discouraged complaints from being filed. The standard of liability set forth in these decisions is premised on two principles: 1) an employer is responsible for the acts of its supervisors, and 2) employers should be encouraged to prevent harassment and employees should be encouraged to avoid or limit the harm from harassment.

In order to accommodate these principles, the Court held that an employer is always liable for a supervisor’s harassment if it culminates in a tangible employment action.

Hubbell, Mich.; Other contributory causes: erysipelas, 4 ds.; Duration: 7 ds.; Signed: Chas A.

42; SAARI, JOHN; Born: unknown; Place of birth: Finland; Date of death: Dec 23, 1924; Time of death: 6 am.; Age: about 88 yrs.; Cause of death: general debility; Attended by signer from: Jan 10, 1924; Attended by signer to: Dec 23, 1924; Alive: Dec 21, 1924; Father: unknown; Birth place of father: unknown; Mother: unknown; Birth place of mother: unknown; Sex: male; Color or race: white; Marital status: widowed; Spouse: unknown; Residence: Stanton township; Length of stay (in this place): 11 yrs.; Occupation: retired; Informant: Wm. plus; Operation: uncertain; Operation: no; Autopsy: no; Test confirming diagnosis: sputum ex.; Signed: Geo Mc Waldie; Houghton; Date signed: Apr 26, 1929; Place of burial: Kewenaw Bay; Date of burial: Apr 29, 1929; Undertaker: Victor Watia; Address of undertaker: Hancock. 57; SAARI, LEMPI; Born: Dec 3, 1914; Place of birth: Mich.; Date of death: Dec 3, 1914; Time of death: 5 a.m.; Age: no yrs. no d.; Cause of death: premature birth; Attended by signer from: Dec 2, 1914; Attended by signer to: Dec 3, 1914; Alive: Dec 2, 1914; Father: Jacob Saari; Birth place of father: Finland; Mother: Ida Rantala; Birth place of mother: Finland; Sex: female; Color or race: white; Informant: Jacob Saari.

infirmary; Signed: Alfred La Bine; Houghton, Mich.; Date signed: Dec 26, 1924; Place of burial: Lakeside, Hancock; Date of burial: Dec 26, 1924; Undertaker: John R. records; Hospital: Copper country sanatorium; Duration: 6 mos. 33; SAATANIOENEN, ANNA HILMA; Born: Apr 26, 1887; Place of birth: Finland; Date of death: Oct 27, 1910; Time of death: 5 a.m.; Age: 23 yrs. 1 d.; Cause of death: epilepsy; Attended by signer from: Mar 4, 1910; Attended by signer to: Mar 28, 1910; Alive: Mar 28, 1910; Father: John Saastanioenen; Birth place of father: Finland; Mother: Inga Kunntinen; Birth place of mother: Finland; Sex: female; Color or race: white; Marital status: single; Occupation: servant girl; Informant: Mrs.

27; SAARI, HUGO LAINE LEONARD; Born: Aug 28, 1910; Place of birth: Michigan; Date of death: Oct 16, 1910; Age: no yrs. 18 d.; Cause of death: no doctor attendance; Father: William Saari; Birth place of father: Finland; Mother: Liina Lokasaari; Birth place of mother: Finland; Sex: male; Color or race: white; Informant: Mrs. Oskar, Mich.; Place of burial: Oskar cemetery; Date of burial: Oct 18, 1910; Undertaker: John D.

58; SAARI, IDA; Born: unknown; Place of birth: Finland; Date of death: Dec 15, 1914; Time of death: 5 p.m.; Age: 22 yrs.; Cause of death: pulmonary tuberculosis; Attended by signer from: Dec 1, 1914; Attended by signer to: Dec 15, 1914; Alive: Dec 15, 1914; Father: unknown; Birth place of father: unknown; Mother: unknown; Birth place of mother: unknown; Sex: female; Color or race: white; Informant: Mrs.