DePaul Law Review Volume 46 Issue 3 Spring 1997 Article 3 You Can Call Me a "Bitch" Just Don't Use the "N-Word": Some Thoughts on Galloway v. General Motors Service Parts Operations and Rodgers v. Western-Southern Life Insurance Co. Robert J. Gregory Follow this and additional works at: https://via.library.depaul.edu/law-review Recommended Citation Robert J. Gregory, You Can Call Me a "Bitch" Just Don't Use the "N-Word": Some Thoughts on Galloway v. General Motors Service Parts Operations and Rodgers v. Western-Southern Life Insurance Co. , 46 DePaul L. Rev. 741 (1997) Available at: https://via.library.depaul.edu/law-review/vol46/iss3/3 This Article is brought to you for free and open access by the College of Law at Via Sapientiae. It has been accepted for inclusion in DePaul Law Review by an authorized editor of Via Sapientiae. For more information, please contact
[email protected]. YOU CAN CALL ME A "BITCH" JUST DON'T USE THE "N-WORD": SOME THOUGHTS ON GALLOWAY V. GENERAL MOTORS SERVICE PARTS OPERATIONS AND RODGERS V. WESTERN-SOUTHERN LIFE INSURANCE CO. Robert J. Gregory* INTRODUCTION Title VII of the Civil Rights Act of 1964 prohibits an employer from discriminating against an individual with respect to his or her "com- pensation, terms, conditions, or privileges of employment, because of such individual's race, color, religion, sex, or national origin."' It has been clear, since at least 1986, that the phrase "terms, conditions or privileges of employment" in Title VII "'is an expansive concept which sweeps within its protective ambit the practice of creating a [hostile or abusive] working environment.' ''2 It has also been clear, since that time, that Title VII extends equally to claims of sexual and racial discrimination based on a hostile working environment.