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In Burlington Industries, Inc. v. Ellerth, 524 U.S. 742 (1998), and Faragher v. Boca Raton, 524 U.S. 775 (1998), the Supreme Court held that an employer may avoid liability for supervisor harassment by proving affirmatively that: The employer did not have the resources to solve the issueThe employee in question is not favored among employees and was not taken seriouslyThe employee's claim did not seem urgent enough to warrant further investigationThe employer exercised reasonable care to prevent and correct the harassment - through training and policy enforcement

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