Plaintiff may not assert a standalone negligence claim for employer’s failure to adopt anti-harassment policies.

The plaintiff asserted claims of sexual harassment under both Title VII and the NJLAD against both her employer and the company president. In dismissing the negligence claim against the employer, the judge held that a negligence theory could be used to establish employer liability under either Title VII or the NJLAD but that it was not a separate cause of action in and of itself.

Case Law Alert, 1^st Quarter 2014