the work and the school milieu to justify a less rigorous” threshold of offensive conduct when plaintiffs claim that sexual harassment has created a hostile educational environment than when plaintiffs seek to support a hostile workplace sexual harassment claim. Donovan v. Mt. Ida College, No. 96-10289 (D.Mass.1997). Even if the measure of harassment in the educational environment is less rigorous than Title VII’s requirement of “severe and pervasive” conduct, the activity alleged in this complaint would miss the hostile environment mark. Holding a university president hable for creating a hostile learning environment solely because of an unpopular speech would also have serious First Amendment implications. See Brown v. Trustees of Boston Univ., 891 F.2d 337, 351 (1st Cir.1989) (<HOLDING>), cert. denied, 496 U.S. 937, 110 S.Ct. 3217,
holding that  ambiguous remarks tending to suggest animus based on age are insufficient standing alone to prove an employers discriminatory intent  holding that it was error to permit the speeches of a university president to be admitted as evidence of discriminatory animus because of the chilling effect that admission of such remarks could have on academic freedom holding that the relevant issue is whether the evidence could support a reasonable factfinders conclusion that a discriminatory animus served as the basis for the employers decision holding in title vii case that the span of time between an employers raciallycharged remarks and the decision to fire the plaintiff is relevant to a determination of whether discriminatory animus motivated the firing holding that remarks made by decisionmakers could be viewed as reflecting discriminatory animus