Tara R. Price


In Robinson v. Jacksonville Shipyards, Inc., the United States District Court for the Middle District of Florida became the first court in the country to hold that the presence of pornography in the workplace-by itself-could constitute a hostile working environment for women, actionable under Title VII of the Civil Rights Act of 1964. Prior to Robinson, courts frequently concluded that Title VII offered no protection to women who felt victimized by the presence of "sexually-oriented pictures and sexual remarks" in the workplace, so long as overt actions targeting particular female employees did not also exist. The opinion-written by Judge Howell W. Melton, Sr.-was quickly lauded and criticized. This Comment considers the groundbreaking aspects of Judge Melton's opinion in Robinson and analyzes how Congress and the courts have responded in the twenty-one years that have elapsed since the decision.