On December 4, 2009, in Duch v. Jakubek, No. 07-3503-cv, the United States Court of Appeals for the Second Circuit found that a supervisor?s “purposeful ignorance” of potential co-worker harassment will not shield an employer from liability under Title VII. In rejecting the notion that a supervisor may bury his or her head in the sand and invoke the “ostrich defense,” the Second Circuit reinforced the rule that liability will be imputed to an employer in situations where a supervisor knew, or in the exercise of reasonable care should have known, of the workplace harassment and failed to take appropriate remedial action.