Can an employee who has engaged in severe or pervasive harassment in the workplace be removed from the workplace if the mere presence of the employee creates a hostile working environment?

We believe that in some cases the mere presence of an employee who has engaged in particularly severe or pervasive harassment can create a hostile working environment. See Paroline v. Unisys Corp., 879 F.2d 100, 106-07 (4th Cir.1989). To avoid liability under Title VII for failing to remedy a hostile environment, employers may even have to remove employees from the workplace if their mere presence would render the working environment hostile. ¹⁹ Once again, we examine whether the mere presence of a harasser would create a hostile environment from the perspective of a reasonable woman.