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The Supreme Court 6/14/04 clarified the circumstances under which employers may assert affirmative defenses to Title VII-based claims that a hostile work environment created by a supervisor culminated in constructive discharge. The Court held that , to establish “constructive discharge,” a plaintiff must show that her work environment was so intolerable that her resignation qualified as a fitting response. If “constructive discharge” is established, the employer may, consistent with the Court’s 1998 decisions in Ellerth and Faragher, assert affirmative defenses that: (i) the employer exercised reasonable care to prevent and correct the harassment, and (ii) the plaintiff unreasonably failed to take advantage of any employer-provided or other opportunities to correct or avoid harm. If, however, the plaintiff resigned in reasonable response to official employer actions changing her employment status − such as humiliating demotions, cuts in pay, or transfers − then the employer may not assert these affirmative defenses. This decision is important for all employers subject to Title VII.