under Title VII and the ICRA). Those differences will be discussed when the Court addresses the damage claims. The plaintiff claims that she was sexually harassed by supervisors and non-supervisors and that the harassment and IBP’s inadequate response resulted in her constructive discharge in May 1996. The sub stantive facts and elements underlying the sexual harassment and constructive discharge claims are integrally related: e.g., the plaintiffs claim of sexual harassment serves as the lynchpin of her constructive discharge claim while a showing of constructive discharge would establish an element of her sexual harassment claim and bar IBP’s assertion of an affirmative defense to the sexual harassment claim. See Jackson v. Arkansas Dept. of Ed., 272 F.3d 1020, 1026 (8th Cir.2001) (<HOLDING>). For purposes of discussion, the Court will
holding that employer has affirmative defense to vicarious liability for supervisors conduct if 1 employer acted promptly and reasonably to prevent and correct the alleged harassment and 2 employee unreasonably failed to take advantage of preventive opportunities offered to her holding that an employer must remedy situation of sexual harassment holding that a constructive discharge would constitute a tangible employment action and prevent the employer from utilizing the affirmative defense to vicarious employer liability for sexual harassment holding that constructive discharge may qualify as a tangible employment action depriving employer of right to assert affirmative defense when a supervisors official act precipitates the constructive discharge holding that trial court did not err in striking plaintiffs negligent hiring employment and entrustment claims against employer where employer acknowledged vicarious liability for employees negligence