Anti-abortion exhibit as sexual harassment?

[Sanford Levinson]

Margo Schlanger writes:

So the statutory question is whether pictures of aborted fetuses create a
>sufficiently severe hostile environment for women, on account of their
>gender -- not whether those pictures are "sexually explicit."
>

I have a hard time understanding how those offended by the pictures could
meet the "on account of their gender" standard, given the obvious fact that
many women oppose reproductive choice and many men were appalled by the
pictures.  I agree that "sexual explicitness" is beside the point:  Surely
a hostile environment, "on account of their gender," would be created by
pictures of fully-clothed women being beaten and the like.  But that's not
this case.

sandy levinson