In response to escalating concerns about workplace violence and harassment,
many employers have adopted, and are well-advised to adopt, no-violence
policies. Such policies are typically broadly drafted not only to prohibit all
forms of physical violence, but to also prohibit verbal forms of violence,
including threatening and abusive language. Likewise, in further efforts to
maintain decorum and civility in the workplace, employers have broadened
non-discrimination and anti-harassment policies to forbid all forms of
inappropriate conduct, including abusive and threatening language. Indeed, the
importance of adopting non-discrimination and anti-harassment policies is now
well-known by most employers, since the Supreme Court in 1998 made it virtually
impossible for employers to defend against hostile environment harassment claims
in the absence of such policies.