the school to the student’s actions. The Plaintiff has not alleged, nor provided any evidence, that the harassing students were acting on behalf of or with authority from SKCS. Therefore, although constructive notice principles properly attach between employer and employee in the Title VII context, they do not attach between the alleged harassing student and the Defendants’ in this Title IX ease. See Rowinsky, 80 F.3d at 1011, n. 11. 4. Title VII’s Criteria Applied to Hostile Learning Environment It is now well established that two forms of sexual harassment violate Title VIPs prohibitions against workplace inequality: 1) quid pro quo and 2) hostile work environment harassment. Tomka v. Seiler Corp., 66 F.3d 1295, 1304-05 (2d Cir.1995); see Meritor, 477 U.S. at 73, 106 S.Ct. at 2408 (<HOLDING>). It is the “hostile environment” category that
holding that a hostile work environment is a form of discrimination that is actionable under the statute holding that noneconomic injury resulting from a hostile environment based on discriminatory sexual harassment is actionable under title vii holding that the elements of a hostile environment claim under title vii equally apply under title ix recognizing that a claim of hostile environment sex discrimination is actionable under title vii recognizing a hostile work environment claim under section 1983