New Maryland federal court judge Paul Grimm has just authored a lengthy opinion that sets forth the burdens a claimant has to overcome in proving a sexual harassment claim in the Fourth Circuit. In Foster v. UMES, Judge Grimm granted summary judgment to the employer on a hostile environment claim of sexual harassment even though there were documented allegations that the harasser had sexually harassed another employee before the claimant. On a better note, Judge Grimm did ruled that the employee had proven her claim of unlawful retaliation – that she was fired because she complained of the sexual harassment. So, the claim is headed for trial.