Seventy-Five Years Later...
Gender-Based Harassment in Schools

Kathryn Scott

On the seventy-fifth anniversary of women's suffrage, we can celebrate significant advances in the legal status, opportunities, and achievements of women in the United States. Whereas in the early twentieth century, sex-segregated education was the norm in secondary schools and higher education, today's public policy upholds integrated institutions. The 1972 Civil Rights Act Title IX prohibited sexual or racial discrimination against students and staff in public education. Since then, legal challenges by students and women activists have resulted in greater gender equity in student access, curriculum, academic achievement, and extra-curricular activities, including sports.
Although women have gained greater access and visibility in the public arena, glaring disparities among the experiences of females, males, and people of color are evident today in both public and private spheres. What has gone largely unnoticed in schools is widespread gender-based harassment-unwanted and unwelcome sexual words or actions that can begin as early as the elementary years (Best 1983; Bogart, et al. 1992).

Sexual harassment and domestic violence became front page news in the 1990s with events such as the Anita Hill-Clarence Thomas Senate hearings, the Navy Tailhook scandal, and the O.J. Simpson trial. Although the 1964 Civil Rights Act made it illegal to engage in sexual or racial discrimination in the workplace, it was not until 1986 that the courts recognized sexual harassment on the job as a form of illegal discrimination and determined that allowing an environment of sexual harassment is unlawful (Meritor State Bank v. Vinson). Since then, plaintiffs have brought successful court suits using a definition of sexual harassment that includes individual cases of harassment as well as a sexually hostile work environment. However, the majority of instances of sexual harassment in the workplace and in schools are never reported.

Identifying Sexual Harassment
What constitutes gender-based harassment? Considerable misunderstanding surrounds the distinction between flirting, which is generally welcomed by the recipient, and sexual harassment, which is demeaning and unwanted. Under the law, the distinction is determined not by the intent of the behavior, but by its impact. Sexual harassment is any type of unwelcome conduct, verbal or nonverbal, directed toward an individual because of his or her gender. It is often more an expression of power than sexual interest and is considered a form of sex discrimination under the law (Seigel, Hallgarth, and Capek 1992). If the initiator believes that she or he is just being "cooquot; or "joking around" but the respondent feels demeaned or degraded, then harassment has occurred (see Chart 1). Targets of unwanted sexual talk or actions, usually females, often feel intimidated, embarrassed, and afraid, often blaming themselves.
Social norms, however, perpetuate and may actually encourage gender-based harassment through the barrage of sexual images in television, music, movies, and other media. Social norms also support gender stereotypes that treat females as sex objects and males as predators. Teachers and administrators frequently overlook or excuse gender-based harassment among peers as "boys will be boys," normal childhood teasing, or teenage flirting. When complaints are made by students, they are often downplayed or ignored by adults (Bogart et al. 1992; Stein 1993). Chart 2 discusses some of the common myths about sexual harassment held by young people and adults alike.

Harassment Is Widespread
Two recent nationwide surveys of students provide substantial documentation of sexual harassment in schools and its effects on students (AAUW 1993; Stein, Marshall, and Tropp 1993). In a survey of more than 1,600 girls and boys that was conducted by Louis Harris and Associates for the educational foundation of the American Association of University Women (AAUW 1993), 81 percent of all students reported at least one incident of school-related sexual harassment, defined as "unwanted and unwelcome sexual behavior which interferes with your life" (see Chart 3). The AAUW study presents further evidence in support of an earlier survey of readers of the magazine Seventeen in which 39 percent of the female respondents indicated that they experienced some form of sexual harassment daily in school-related activities (Stein, Marshall, and Tropp 1993).
Researchers in the AAUW study took a representative sample of African American, Hispanic, and white students in grades 8-11 from seventy-nine schools nationwide. Boys (76 percent) as well as girls (85 percent) reported being targets of sexual harassment, with girls (66 percent) likely to experience harassment more frequently than were boys (49 percent). Peer-to-peer harassment typified the majority of incidents (79 percent), most of which occurred in the classrooms or hallways where other students or adults were likely to be bystanders.

Sexual comments, jokes, gestures, or looks were the most frequent (66 percent) forms of harassment. Girls were more likely to experience almost every form of harassment than were boys (see Chart 3), with the most notable exception that boys were more likely to be harassed by being called gay (23 percent) than were girls (10 percent). Boys were also much more likely to be harassed by other boys alone or in a group (38 percent) than were girls by other girls (13 percent). More than half of all respondents knew of complaints of harassment that had been ignored by school officials.

One-third of harassed students first experienced unwanted sexual talk or actions as early as elementary school, with the majority first aware of unwelcome sexual behavior in the middle school or junior high grades. However, twice as many boys (36 percent) as girls (17 percent) could not remember the grade in which they first encountered sexual harassment. Adults in the school setting (e.g., teachers, coaches, bus drivers) were responsible for almost 20 percent of incidents. Girls (25 percent) in general were more likely than were boys (10 percent) to be targets of adult sexual harassment, with African American girls (33 percent) the most frequent targets.

The greatest gaps between girls' and boys' experiences of harassment reported in the AAUW study appeared in the greater discomfort and educational harm experienced by girls (Chart 4). Boys tended to take sexual overtures in stride with less emotional, educational, or behavioral impact on their lives. Whereas only 24 percent of the boys became "very upset" or "somewhat upset" by their experiences, 70 percent of the girls felt this way. Harassment influenced females to such an extent that a far greater proportion of them stayed home from school, participated less frequently in classroom discussions, had difficulty concentrating in class and studying, and made lower test grades and report card grades as a result of being harassed (see Chart 5). Girls also took greater pains than did boys to avoid the person(s) who harassed them (69 percent) and restricted their activities at school (34 percent).

Understanding Gender-Based Harassment
The differential impact of sexual harassment on females and males should not be surprising, given the greater cultural and structural power generally bestowed on males in U.S. culture. Males learn from a very early age that they can use informal power to intimidate others verbally and physically, often in quite socially acceptable ways. In contrast, females are socialized to eschew power through nurturing roles and put other people's feelings first (Stein 1993). They may at times stifle their own feelings so as not to hurt another and, in the process, internalize others' condescension, disapproval, or even hostility, resulting in their lowered self-esteem. As a consequence, females may not recognize situations of harassment or abuse.
Beginning in the elementary school years and throughout adulthood, females who do object to harassment are often silenced through ridicule, blame, or exclusion (Bogart et al. 1992). For example, females who respond negatively to being harassed may be accused of being "too sensitive" or "not being able to take a joke." Or they may be accused by males of having "asked for it" by wearing attractive clothes. The fear of disapproval or rejection by males may also be sufficient to create a wall of silence supported by other women who do not want to take the risk of "rocking the boat." Especially during middle school years, both boys and girls are more likely to adopt peer norms at whatever price to achieve acceptance.

Legal Sanctions Against Harassment
Until the 1990s, there were no significant legal decisions defining a school's responsibility should gender-based harassment occur. In 1992, the U.S. Supreme Court unanimously ruled in the case of Franklin v. Gwinnett County Public Schools that under Title IX of 1972 a student could seek monetary damages from the schools and school officials. The student bringing charges had been subjected to unwanted sexual attention from a high school social studies teacher in suburban Atlanta, Georgia, and was discouraged from filing charges by the district.
Another ground-breaking case was the first ruling on student-to-student harassment by the U.S. Department of Education that determined in 1993 that the Minnesota Eden Prairie Schools had violated federal law in "failing to take timely and effective responsive action to address . . . multiple or severe acts of sexual harassment" (cited in Eaton 1994). This decision stemmed from complaints filed on behalf of eight elementary-grade girls who, while riding the school bus, had been repeated targets of a group of boys calling them "bitches" with "stinky vaginas."

In recognizing peer harassment, the Office for Civil Rights (OCR) declared that a school district violated Title IX "when it knew or should have known that a sexually hostile environment exists due to student-to-student harassment." A hostile environment was defined as one where "acts of a sexual nature are sufficiently severe or pervasive to impair educational benefits," including school-related activities such as school busing (cited in Eaton 1994). Although the Eden Prairie Schools had policies in effect prohibiting student-to-student harassment, they had considered the bus incidents as instances of "bad language," while the OCR considered the instances from the point of view of the victims, declaring "there is no question that even the youngest girls understood that the language and conduct being used were expressions of hostility toward them on the basis of their sex."

Policy and Prevention
With the growing public awareness of gender-based harassment and willingness of courts to permit monetary restitution, educators have an increased impetus to ensure that their schools are free from sexually hostile environments and that students are aware of their right to a gender-safe education. Districts have the obligation to develop and implement a school policy to handle the problem (see Chart 6). Although many school districts have written policies barring harassment, only rarely are they fully understood or enforced (Eaton 1994).
By involving teachers, administrators, and students in creating a policy, schools can begin to address the issue at the grassroots level. With a clear statement of what constitutes gender-based harassment and a complaint procedure that ensures confidentiality, educators can send a message that complaints will be taken seriously and that students will be protected from retaliation. Parents and school staff also need to be educated about the problem and informed of the policy.

Although most acts of gender-based harassment occur in school corridors and classrooms in full view of others, most teachers and administrators are unclear about what constitutes illegal harassment or are unaware of the widespread prevalence of gender-based harassment and its impact on students. No longer is it advisable for teachers or administrators to ignore student harassment or dismiss student complaints. Educators and parents have a responsibility to teach today's youth respect for others, educate them to respond to abuse, and intervene where a hostile climate exists.

American Association of University Women. Hostile Hallways: The AAUW Survey on Sexual Harassment in America's Schools. Washington, D.C.: American Association of University Women Educational Foundation, 1993.Best, Raphaella. We've All Got Scars: What Boys and Girls Learn in Elementary School. Bloomington: Indiana University Press, 1983.Bogart, K., S. Simmons, N. Stein, and E. P. Tomaszewski. "Breaking the Silence: Sexual and Gender-Based Harassment in Elementary, Secondary, and Post-Secondary Education." In Sex Equity and Sexuality in Education, edited by S. S. Klein. Albany: State University of New York Press, 1992.Eaton, Susan. "Sexual Harassment at an Early Age: New Cases Are Changing the Rules for Schools." In The Best of the Harvard Education Letter. Cambridge, Massachusetts: Harvard Graduate School of Education, 1994.Seigel, D. L., S. A. Hallgarth, and M. E. Capek. Sexual Harassment: Research and Resources. New York: The National Council for Research on Women, 1992.Stein, Nan, N. L. Marshall, and L. R. Tropp. Secrets in Public: Sexual Harassment in Our Schools. Wellesley, Massachusetts: Wellesley College Center for Research on Women, 1993.Stein, Nan D. "It Happens Here, Too: Sexual Harassment and Child Sexual Abuse in Elementary and Secondary Schools." In Gender and Education, edited by S. K. Biklen and D. Pollard. Ninety-Second Yearbook of the National Society for the Study of Education. Chicago: University of Chicago Press, 1993.

Kathryn Scott, professor of educational theory and practice at Florida State University, has published more than twenty articles and book chapters on gender in education. She teaches social studies education for elementary teachers.