Remember Graydon Snyder, the professor at Chicago Theological Seminary who got a sexual harassment reprimand for exploring the role of intent in sin by reciting a story from the Talmud about a man who falls off a roof, lands on a woman, and accidentally has intercourse with her?

Remember J. Donald Silva, the writing instructor at the University of New Hampshire who got a sexual harassment suspension for classroom use of sexual metaphors-like a famous belly dancer’s comparison of her craft to "Jell-O on a plate, with a vibrator under the plate"-that some female students found offensive? (Silva later won a judicial ruling that the suspension violated the First Amendment.)

Remember the student at Tufts University who was temporarily suspended for selling T-shirts inscribed with 15 reasons "Why Beer is Better than Women at Tufts"?

Such examples create a temptation in some quarters to dismiss reflexively claims of sexual harassment, and sex discrimination generally, as ideologically tinged whining over trifles by politically correct women whose actual agenda is censorship.

But now comes a timely reminder-from Normal, Ill.-of the real sexual harassment that stalks many women, especially blue-collar women breaking into traditionally male workplaces, who are often subjected to crude sexist vilification of a sort rarely experienced by pampered propagandists of PC paranoia who populate the professoriate.

Normal is home to the now infamous factory owned by Mitsubishi Motor Manufacturing of America Inc. The company was hit by the Equal Employment Opportunity Commission on April 9 with the largest sexual harassment suit in history, alleging rampant harassment of as many as 500 women at the plant since it opened in 1988.

Amid reports of retaliation and even death threats by co-workers against complaining women, the company has launched a cheeky and ill-advised counterattack. On April 22, it bused 2,000 workers to Chicago to picket the EEOC office there.

But notwithstanding the denials by some employees-who fear that the publicity attending the suit could threaten the future of the money-losing plant and their own high-paying jobs- published reports suggest ample evidence that the factory was pervaded by raw and sometimes vicious sexual harassment.

Consider the experience of Sandra Rushing, as reported by The Washington Post:

For 11 months the teasing and bawdy humor she saw was not unlike summer construction jobs she’s had…. But when she was transferred to the chassis line, things were altogether different.

The jokes grew more coarse. The men would gather around her, she said, touching her breasts and reaching between her legs to touch her crotch. They drew pictures of her engaged in sexual activities, labeled with her name, and placed them on the cars as they moved through the assembly line, weaving through dozens of workers. One night, a male co-worker exposed himself to her.

Rushing said she often complained to her supervisor and asked him to step in and stop the harassment, but things only got worse. One evening, as the night shift ended, four men gathered around her, demanding she have sex with them. They said if she didn’t agree, they would force her.

This evidence does not appear to reflect anything especially abnormal about the Normal, Ill., species of macho man. It’s an all-American town, albeit one running on Japanese money. And while the sexism that imbues Japanese business culture may help explain why top management condoned such egregious misconduct for so long, the men doing the harassing were all Americans.

In short, what happened to women in Normal appears illustrative of what would happen to women in a lot of factories and shipyards and other traditionally male workplaces around the United States in the absence of active steps by management and unions to clamp down on harassment of, and discrimination against, women by male supervisors and co-workers.

And if the allegations by Rushing and others hold up in court, a ruling (or settlement) imposing a painful dose of liability on Mitsubishi would be an appropriate reminder that employers have a legal duty to police and prevent such conduct.

The kind of unwelcome grabbing, touching, and coercive demands for sex that were apparently widespread at the Mitsubishi plant clearly satisfies even the narrowest definition of sexual harassment. The harder question lurking in the background of the case is where to draw the line between sexual harassment and protected speech when dealing with crude sexual or sexist comments, verbal insults, and other nonphysical abuse that stops short of threatening violence or demanding sex.

The Supreme Court has offered little guidance in this area. And some judges have gone overboard, like the one so bent on purging pornography from a shipyard that he barred male employees from (among other things) displaying photos of their wives in swimsuits on their desks, and the one who warned against use of "sexist" job titles like "draftsman."

Judges like these seem to have forgotten that the First Amendment protects even sexist and offensive speech, whether uttered by factory workers or professors. Sound public policy, as well as the First Amendment, argues against creating a regime of indirect censorship that chills healthy social discourse, as courts do when they threaten employers with such broad liability as to create pressure to stamp out any and all comments that might arguably be offensive to the most hypersensitive of employees.

Some of the sexist behavior at the Mitsubishi factory, like the teasing and bawdy humor to which Rushing was exposed when she started out, seems sufficiently expressive, and innocuous, to warrant protection from governmental or judicial sanction.

But what about the male workers who posted lists on men’s-room walls ranking women in the plant by their estimated breast size and who taunted them about their rankings? What about the pornographic drawings of Rushing and other female workers that were placed on cars moving down the assembly line? What about the men who routinely referred to women as "sluts," "bitches," and "whores," and hurled crude insults in their faces? Can mere words and pictures like these, however gross, properly be the basis for imposing liability on the employer?

The answers are not self-evident. As Judge Edith Jones of the U.S. Court of Appeals for the 5th Circuit observed May 10 last year, in overturning the verdict in DeAngelis v. El Paso Municipal Police Officers Association, when "applied to sexual harassment claims founded solely on verbal insults, pictorial or literary matter, [federal law] imposes content-based, viewpoint-discriminatory restrictions on speech…. Whether such applications … are necessarily unconstitutional has not yet been fully explored."

Judge Jones overturned a $60,000 sexual harassment verdict for Sylvia DeAngelis, the first female police sergeant in El Paso, Texas, who sued based on sexist, boorish jibes directed at her and other female officers by an anonymous columnist in a police association newsletter. Jones avoided the First Amendment question by stressing that the statutory ban on sexual harassment "cannot remedy every tasteless joke or groundless rumor that confronts women in the workplace," but rather is aimed at harassment "so egregious as to … destroy [women’s] equal opportunity in the workplace."

A few scholars, such as Professor Kingsley Browne of Wayne State University Law School in Detroit, have suggested that the First Amendment protects all verbal or symbolic expression in the workplace from sanction for sexist (or racist) content-no matter how severe the vilification, no matter how injurious the intent of the harasser or the effect on the target, and no matter how much power the harasser has over the target.

Such absolutism goes too far. By borrowing from the common law tort of intentional infliction of emotional distress, we can draw a tolerably clear line distinguishing offensive remarks like those directed at DeAngelis, which are properly viewed as protected speech, from the far more severe, face-to-face verbal abuse to which women at the Mitsubishi plant have been subjected.

The key is to distinguish generalized statements of opinion-which should enjoy absolute protection no matter how sexist-from sex-based vilification that is (1) targeted on a particular employee or a small beleaguered group, and is so extreme that it (2) amounts to intentional infliction of severe emotional distress and (3) causes the target reasonably to feel seriously injured in her effectiveness or status on the job.

By this standard, a woman who has no more to complain about than some pornographic pictures hanging on men’s lockers, or sexist graffiti in the men’s room, or a stray sexist crack, has not been sexually harassed. But Sandra Rushing, and a lot of other women at the Mitsubishi plant, would apparently qualify for substantial awards of damages.