1. Clarification of the "Severe or Pervasive " Standard.
Title VII prohibits discrimination in the "terms, conditions, or privileges of
employment " because of sex. 42 U.S.C. § 2000e-2(a)(l). In Meritor Savings
Bank v. Vinson, 477 U.S. 57 (1986), and Harris v. Forklift Sys., Inc., 510 U.S.
17 (1993), this Court held that a hostile work environment exists when
harassment is "sufficiently severe or pervasive to alter the conditions of
employment. " The circuits, however, apply this standard inconsistently: some
require extreme or repeated conduct, while others allow juries to consider fewer
but severe incidents or persistent gender-based slurs.
Question U Whether this Court should clarify or modify the "severe or
pervasive " standard to ensure uniform national protection under Title VII.

2. Entrenched Circuit Conflict.
The Eighth Circuit in Paskert v. Kemna ASA Auto Plaza, Inc., 950 F.3d 535
(8th Cir. 2020), held that repeated sexist remarks and unwanted touching were
not actionable, while the Seventh Circuit in Passananti v. Cook County, 689
F.3d 655 (7th Cir. 2012), held that repeated use of the word "bitch " could
establish a hostile environment. The First {Gerald v. Univ. ofP.R., 707 F.3d 7
(1st Cir. 2013)) and Ninth Circuits {Ellison v. Brady, 924 F.2d 872 (9th Cir.
1991)) have likewise adopted broader approaches.
Question 2- Whether review is warranted to resolve the entrenched circuit split
regarding the application of Title VIPs "severe or pervasive " standard.

3. Contradictory Jury Verdict.
At trial, the jury found that petitioner endured repeated intentional sexual
batteries, awarding both compensatory and punitive damages, yet rejected her
Title VII hostile work environment claim. This outcome cannot be reconciled
with Meritor, Harris, and Oncale v. Sundowner Offshore Servs., Inc., 523 U.S.
75 (1998), which recognize that unwanted sexual touching is harassment
"because of sex. "
Question 3: Whether a jury may lawfully find intentional sexual battery while
simultaneously denying a Title VII hostile work environment claim arising
from the same conduct, and whether courts must correct such contradictions to
preserve the integrity of anti-discrimination law.

4. Miscarriage of Justice in Damages.
Despite overwhelming medical evidence of post-traumatic stress disorder,
repeated hospitalizations, long-term psychiatric treatment, and permanent
disability, the jury awarded only $50,000 in compensatory damages —far below
comparable awards such as Turley v. ISG Lackawanna, Inc., 774 F.3d 140 (2d
Cir. 2014) ($1.32 million). The District Court compounded the error by
attributing petitioner 's condition to decades-old spousal abuse, unsupported by
medical evidence.
Question 4* Whether such a grossly inadequate awar

Whether the Supreme Court should clarify the 'severe or pervasive' standard for hostile work environment claims under Title VII to ensure uniform national protection