The Civil Rights Act of 1991 added provisions to Title VII protections including expanding the rights of women to sue and collect compensatory and punitive damages for sexual discrimination or harassment, and the case of "Ellison v. Brady" (US Court of Appeals for the Ninth Circuit – 924 F.2d 872 (9th Cir. 1991)) resulted in rejecting the reasonable person standard in favor of the "reasonable woman standard" which allowed for cases to be analyzed from the perspective of the complainant and not the defendant. However, some legal scholars have argued this does not go far enough and that the reasonable person standard also needs to take intersectionality into account. Also in 1991, "Jenson v. Eveleth Taconite Co." became the first sexual harassment case to be given class action status paving the way for others. Seven years later, in 1998, through that same case, new precedents were established that increased the limits on the "discovery" process in sexual harassment cases, that then allowed psychological injuries from the litigation process to be included in assessing damages awards. In the same year, the courts concluded in "Faragher v. City of Boca Raton, Florida", and "Burlington v. Ellerth", that employers are liable for harassment by their employees. Moreover, "Oncale v. Sundowner Offshore Services" set the precedent for same-sex harassment, and sexual harassment without motivation of "sexual desire", stating that any discrimination based on sex is actionable so long as it places the victim in an objectively disadvantageous working condition, regardless of the gender of either the victim, or the harasser.