introduction to medical personal statement

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Medical School Personal Statement Examples That Got 6 Acceptances

Featured Admissions Expert: Dr. Monica Taneja, MD

These 30 exemplary medical school personal statement examples come from our students who enrolled in one of our application review programs. Most of these examples led to multiple acceptance for our students. For instance, the first example got our student accepted into SIX medical schools. Here's what you'll find in this article: We'll first go over 30 medical school personal statement samples, then we'll provide you a step-by-step guide for composing your own outstanding statement from scratch. If you follow this strategy, you're going to have a stellar statement whether you apply to the most competitive or the easiest medical schools to get into .

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Article Contents 36 min read

Stellar medical school personal statement examples that got multiple acceptances, medical school personal statement example #1.

I made my way to Hillary’s house after hearing about her alcoholic father’s incarceration. Seeing her tearfulness and at a loss for words, I took her hand and held it, hoping to make things more bearable. She squeezed back gently in reply, “thank you.” My silent gesture seemed to confer a soundless message of comfort, encouragement and support.

Through mentoring, I have developed meaningful relationships with individuals of all ages, including seven-year-old Hillary. Many of my mentees come from disadvantaged backgrounds; working with them has challenged me to become more understanding and compassionate. Although Hillary was not able to control her father’s alcoholism and I had no immediate solution to her problems, I felt truly fortunate to be able to comfort her with my presence. Though not always tangible, my small victories, such as the support I offered Hillary, hold great personal meaning. Similarly, medicine encompasses more than an understanding of tangible entities such as the science of disease and treatment—to be an excellent physician requires empathy, dedication, curiosity and love of problem solving. These are skills I have developed through my experiences both teaching and shadowing inspiring physicians.

Medicine encompasses more than hard science. My experience as a teaching assistant nurtured my passion for medicine; I found that helping students required more than knowledge of organic chemistry. Rather, I was only able to address their difficulties when I sought out their underlying fears and feelings. One student, Azra, struggled despite regularly attending office hours. She approached me, asking for help. As we worked together, I noticed that her frustration stemmed from how intimidated she was by problems. I helped her by listening to her as a fellow student and normalizing her struggles. “I remember doing badly on my first organic chem test, despite studying really hard,” I said to Azra while working on a problem. “Really? You’re a TA, shouldn’t you be perfect?” I looked up and explained that I had improved my grades through hard work. I could tell she instantly felt more hopeful, she said, “If you could do it, then I can too!” When she passed, receiving a B+;I felt as if I had passed too. That B+ meant so much: it was a tangible result of Azra’s hard work, but it was also symbol of our dedication to one another and the bond we forged working together.

My passion for teaching others and sharing knowledge emanates from my curiosity and love for learning. My shadowing experiences in particular have stimulated my curiosity and desire to learn more about the world around me. How does platelet rich plasma stimulate tissue growth? How does diabetes affect the proximal convoluted tubule? My questions never stopped. I wanted to know everything and it felt very satisfying to apply my knowledge to clinical problems.

Shadowing physicians further taught me that medicine not only fuels my curiosity; it also challenges my problem solving skills. I enjoy the connections found in medicine, how things learned in one area can aid in coming up with a solution in another. For instance, while shadowing Dr. Steel I was asked, “What causes varicose veins and what are the complications?” I thought to myself, what could it be? I knew that veins have valves and thought back to my shadowing experience with Dr. Smith in the operating room. She had amputated a patient’s foot due to ulcers obstructing the venous circulation. I replied, “veins have valves and valve problems could lead to ulcers.” Dr. Steel smiled, “you’re right, but it doesn’t end there!” Medicine is not disconnected; it is not about interventional cardiology or orthopedic surgery. In fact, medicine is intertwined and collaborative. The ability to gather knowledge from many specialties and put seemingly distinct concepts together to form a coherent picture truly attracts me to medicine.

It is hard to separate science from medicine; in fact, medicine is science. However, medicine is also about people—their feelings, struggles and concerns. Humans are not pre-programmed robots that all face the same problems. Humans deserve sensitive and understanding physicians. Humans deserve doctors who are infinitely curious, constantly questioning new advents in medicine. They deserve someone who loves the challenge of problem solving and coming up with innovative individualized solutions. I want to be that physician. I want to be able to approach each case as a unique entity and incorporate my strengths into providing personalized care for my patients. Until that time, I may be found Friday mornings in the operating room, peering over shoulders, dreaming about the day I get to hold the drill.

Let's take a step back to consider what this medical school personal statement example does, not just what it says. It begins with an engaging hook in the first paragraph and ends with a compelling conclusion. The introduction draws you in, making the essay almost impossible to put down, while the conclusion paints a picture of someone who is both passionate and dedicated to the profession. In between the introduction and conclusion, this student makes excellent use of personal narrative. The anecdotes chosen demonstrate this individual's response to the common question, " Why do you want to be a doctor ?" while simultaneously making them come across as compassionate, curious, and reflective. The essay articulates a number of key qualities and competencies, which go far beyond the common trope, I want to be a doctor because I want to help people.

This person is clearly a talented writer, but this was the result of several rounds of edits with one of our medical school admissions consulting team members and a lot of hard work on the student's part. If your essay is not quite there yet, or if you're just getting started, don't sweat it. Do take note that writing a good personal essay takes advanced planning and significant effort.

I was one of those kids who always wanted to be doctor. I didn’t understand the responsibilities and heartbreaks, the difficult decisions, and the years of study and training that go with the title, but I did understand that the person in the white coat stood for knowledge, professionalism, and compassion. As a child, visits to the pediatrician were important events. I’d attend to my hair and clothes, and travel to the appointment in anticipation. I loved the interaction with my doctor. I loved that whoever I was in the larger world, I could enter the safe space of the doctor’s office, and for a moment my concerns were heard and evaluated. I listened as my mother communicated with the doctor. I’d be asked questions, respectfully examined, treatments and options would be weighed, and we would be on our way. My mother had been supported in her efforts to raise a well child, and I’d had a meaningful interaction with an adult who cared for my body and development. I understood medicine as an act of service, which aligned with my values, and became a dream.

I was hospitalized for several months as a teenager and was inspired by the experience, despite the illness. In the time of diagnosis, treatment and recovery, I met truly sick children. Children who were much more ill than me. Children who wouldn’t recover. We shared a four-bed room, and we shared our medical stories. Because of the old hospital building, there was little privacy in our room, and we couldn’t help but listen-in during rounds, learning the medical details, becoming “experts” in our four distinct cases. I had more mobility than some of the patients, and when the medical team and family members were unavailable, I’d run simple errands for my roommates, liaise informally with staff, and attend to needs. To bring physical relief, a cold compress, a warmed blanket, a message to a nurse, filled me with such an intense joy and sense of purpose that I applied for a volunteer position at the hospital even before my release.

I have since been volunteering in emergency departments, out-patient clinics, and long term care facilities. While the depth of human suffering is at times shocking and the iterations of illness astounding, it is in the long-term care facility that I had the most meaningful experiences by virtue of my responsibilities and the nature of the patients’ illnesses. Charles was 55 when he died. He had early onset Parkinson’s Disease with dementia that revealed itself with a small tremor when he was in his late twenties. Charles had a wife and three daughters who visited regularly, but whom he didn’t often remember. Over four years as a volunteer, my role with the family was to fill in the spaces left by Charles’ periodic inability to project his voice as well as his growing cognitive lapses. I would tell the family of his activities between their visits, and I would remind him of their visits and their news. This was a hard experience for me. I watched as 3 daughters, around my own age, incrementally lost their father. I became angry, and then I grew even more determined.

In the summer of third year of my Health Sciences degree, I was chosen to participate in an undergraduate research fellowship in biomedical research at my university. As part of this experience, I worked alongside graduate students, postdoctoral fellows, medical students, physicians, and faculty in Alzheimer’s research into biomarkers that might predict future disease. We collaborated in teams, and by way of the principal investigator’s careful leadership, I learned wherever one falls in terms of rank, each contribution is vital to the outcome. None of the work is in isolation. For instance, I was closely mentored by Will, a graduate student who had been in my role the previous summer. He, in turn, collaborated with post docs and medical students, turning to faculty when roadblocks were met. While one person’s knowledge and skill may be deeper than another’s, individual efforts make up the whole. Working in this team, aside from developing research skills, I realized that practicing medicine is not an individual pursuit, but a collaborative commitment to excellence in scholarship and leadership, which all begins with mentorship.

Building on this experience with teamwork in the lab, I participated in a global health initiative in Nepal for four months, where I worked alongside nurses, doctors, and translators. I worked in mobile rural health camps that offered tuberculosis care, monitored the health and development of babies and children under 5, and tended to minor injuries. We worked 11-hour days helping hundreds of people in the 3 days we spent in each location. Patients would already be in line before we woke each morning. I spent each day recording basic demographic information, blood pressure, pulse, temperature, weight, height, as well as random blood sugar levels, for each patient, before they lined up to see a doctor. Each day was exhausting and satisfying. We helped so many people. But this satisfaction was quickly displaced by a developing understanding of issues in health equity.

My desire to be doctor as a young person was not misguided, but simply naïve. I’ve since learned the role of empathy and compassion through my experiences as a patient and volunteer. I’ve broadened my contextual understanding of medicine in the lab and in Nepal. My purpose hasn’t changed, but what has developed is my understanding that to be a physician is to help people live healthy, dignified lives by practicing both medicine and social justice.

28 More Medical School Personal Statement Examples That Got Accepted

What my sister went through pushed me to strengthen my knowledge in medical education, patient care, and research. These events have influenced who I am today and helped me determine my own passions. I aspire to be a doctor because I want to make miracles, like my sister, happen. Life is something to cherish; it would not be the same if I did not have one of my four sisters to spend it with. As all stories have endings, I hope that mine ends with me fulfilling my dream of being a doctor, which has been the sole focus of my life to this point. I would love nothing more than to dedicate myself to such a rewarding career, where I achieve what those doctors did for my family. Their expertise allowed my sister to get all the care she needed for her heart, eyes, lungs, and overall growth. Those physicians gave me more than just my little sister, they gave me the determination and focus needed to succeed in the medical field, and for that, I am forever grateful. ","label":"Medical School Personal Statement Example #3","title":"Medical School Personal Statement Example #3"}]" code="tab4" template="BlogArticle">

I came to America, leaving my parents and friends behind, to grasp my chance at a better future. I believe this chance is now in front of me. Medicine is the only path I truly desire because it satisfies my curiosity about the human body and it allows me to directly interact with patients. I do not want to miss this chance to further hone my skills and knowledge, in order to provide better care for my patients. ","label":"Medical School Personal Statement #4","title":"Medical School Personal Statement #4"}]" code="tab5" template="BlogArticle">

The time I have spent in various medical settings has confirmed my love for the field. Regardless of the environment, I am drawn to patients and their stories, like that scared young boy at AMC. I am aware that medicine is a constantly changing landscape; however, one thing that has remained steadfast over the years is putting the patient first, and I plan on doing this as a physician. All of my experiences have taught me a great deal about patient interaction and global health, however, I am left wanting more. I crave more knowledge to help patients and become more useful in the healthcare sector. I am certain medical school is the path that will help me reach my goal. One day, I hope to use my experiences to become an amazing doctor like the doctors that treated my sister, so I can help other children like her. ","label":"Medical School Personal Statement Example #5","title":"Medical School Personal Statement Example #5"}]" code="tab6" template="BlogArticle">

My interest in the field of medicine has developed overtime, with a common theme surrounding the importance of personal health and wellness. Through my journey in sports, travelling, and meeting some incredible individuals such as Michael, I have shifted my focus from thinking solely about the physical well-being, to understanding the importance of mental, spiritual, and social health as well. Being part of a profession that emphasizes continuous education, and application of knowledge to help people is very rewarding, and I will bring compassion, a hard work ethic and an attitude that is always focused on bettering patient outcomes. ","label":"Medical School Personal Statement Example # 7","title":"Medical School Personal Statement Example # 7"}]" code="tab8" template="BlogArticle">

Medicine embodies a hard science, but it is ultimately a profession that treats people. I have seen firsthand that medicine is not a \u201cone-treatment-fits-all\u201d practice, as an effective physician takes a holistic approach. This is the type of physician I aspire to be: one who refuses to shy away from the humanity of patients and their social context, and one who uses research and innovation to improve the human condition. So, when I rethink \u201cwhy medicine?\u201d, I know it\u2019s for me \u2013 because it is a holistic discipline, because it demands all of me, because I am ready to absorb the fascinating knowledge and science that dictates human life, and engage with humanity in a way no other profession allows for. Until the day that I dawn the coveted white coat, you can find me in inpatient units, comforting the many John\u2019s to come, or perhaps at the back of an operating room observing a mitral valve repair \u2013 dreaming of the day the puck is in my zone. ","label":"Medical School Personal Statement Example #8","title":"Medical School Personal Statement Example #8"}]" code="tab9" template="BlogArticle">

When I signed up to be a live DJ, I didn't know that the oral skills I practiced on-air would influence all aspects of my life, let alone lead me to consider a career in the art of healing. I see now, though, the importance of these key events in my life that have allowed me to develop excellent communication skills--whether that be empathic listening, reading and giving non-verbal cues, or verbal communication. I realize I have always been on a path towards medicine. Ultimately, I aim to continue to strengthen my skills as I establish my role as a medical student and leader: trusting my choices, effectively communicating, and taking action for people in need. ","label":"Medical School Personal Statement Example #9","title":"Medical School Personal Statement Example #9"}]" code="tab10" template="BlogArticle">

\u201cWhy didn\u2019t I pursue medicine sooner?\u201d Is the question that now occupies my mind. Leila made me aware of the unprofessional treatment delivered by some doctors. My subsequent activities confirmed my desire to become a doctor who cares deeply for his patients and provides the highest quality care. My passion for research fuels my scientific curiosity. I will continue to advocate for patient equality and fairness. Combining these qualities will allow me to succeed as a physician. ","label":"Medical School Personal Statement Example #10","title":"Medical School Personal Statement Example #10"}]" code="tab11" template="BlogArticle">

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Please note that all personal statements are the property of the students who wrote them, re-printed with permission. Names and identifying characteristics have been changed. Plagiarism detection software is used when evaluating personal statements. Plagiarism is grounds for disqualification from the application. ","label":"NOTE","title":"NOTE"}]" code="tab2" template="BlogArticle">

As one of the most important  medical school requirements , the personal statement tells your story of why you decided to pursue the medical profession. Keep in mind that personal statements are one of the key factors that affect medical school acceptance rates . This is why it's important to write a stellar essay!

“Personal statements are often emphasized in your application to medical school as this singular crucial factor that distinguishes you from every other applicant. Demonstrating the uniqueness of my qualities is precisely how I found myself getting multiple interviews and offers into medical school.” – Dr. Vincent Adeyemi, MD, Emory University school of Medicine

But this is easier said than done. In fact, medical school personal statements remain one of the most challenging parts of students' journeys to medical school. Here's our student Melissa sharing her experience of working on her personal statement:

"I struggled making my personal statement personal... I couldn't incorporate my feelings, motives and life stories that inspired me to pursue medicine into my personal statement" -Melissa, BeMo Student

Our student Rishi, who is now a student at the Carver College of Medicine , learned about the importance of the medical school personal statement the hard way:

"If you're a reapplicant like me, you know we all dread it but you have to get ready to answer what has changed about your application that we should accept you this time. I had an existing personal statement that did not get me in the first time so there was definitely work to be done." - Rishi, BeMo Student, current student at the Carver College of Medicine

The importance of the medical school personal statement can actually increase if you are applying to medical school with any red flags or setbacks, as our student Kannan did:

"I got 511 on my second MCAT try... My goal was anything over median of 510 so anything over that was honestly good with me because it's just about [creating] a good personal statement at that point... I read online about how important the personal statement [is]... making sure [it's] really polished and so that's when I decided to get some professional help." - Kannan, BeMo Student, current student at the Schulich School of Medicine  

As you can see from these testimonials, your medical school personal statement can really make a difference. So we are here to help you get started writing your own personal statement. Let's approach this step-by-step. Below you will see how we will outline the steps to creating your very best personal statement. And don't forget that if you need to see more examples, you can also check out our AMCAS personal statement examples, AACOMAS personal statement examples and TMDSAS personal statement examples to further inspire you!

Here's a quick run-down of what we'll cover in the article:

Now let's dive in deeper!

#1 Understanding the Qualities of a Strong Med School Personal Statement

Before discussing how to write a strong medical school personal statement, we first need to understand the qualities of a strong essay. Similar to crafting strong medical school secondary essays , writing a strong personal statement is a challenging, yet extremely important, part of your MD or MD-PhD programs applications. Your AMCAS Work and Activities section may show the reader what you have done, but the personal statement explains why. This is how Dr. Neel Mistry, MD and our admissions expert, prepared for his medical school personal statement writing:

"The personal statement is an opportunity for you to shine and really impress the committee to invite you for an interview. The personal statement is your chance to be reflective and go beyond what is stated on your CV and [activities]. In order to stand out, it is important to answer the main questions [of medical school personal statements] well: a bit about yourself and what led you to medicine, why you would make an ideal medical student and future physician, what attracts you to [medicine], and what sets you apart from the other candidates. The key here is answering the last two questions well. Most candidates simply highlight what they have done, but do not reflect on it or mention how what they have done has prepared them for a future medical career." - Dr. Neel Mistry, MD

“my essay also focused on volunteering in the local health clinic during the many summer breaks. volunteering was more than just another activity to tick off my bucket list for my medical school … i volunteered because i wanted to view medical practice through the lenses of already qualified doctors, not because i needed a reason to be a doctor. i understood that the admissions committee would be more interested in how i was motivated.” – dr. vincent adeyemi..

A personal statement should be deeply personal, giving the admissions committee insight into your passions and your ultimate decision to pursue a career in medicine. A compelling and introspective personal statement can make the difference between getting an interview and facing medical school rejection . Review our blogs to find out how to prepare for med school interviews and learn the most common medical school interview questions .

As you contemplate the task in front of you, you may be wondering what composing an essay has to do with entering the field of medicine. Many of our students were surprised to learn that medical school personal statements are so valued by med schools. The two things are more closely related than you think. A compelling personal statement demonstrates your written communication skills and highlights your accomplishments, passions, and aspirations. The ability to communicate a complex idea in a short space is an important skill as a physician. You should demonstrate your communication skills by writing a concise and meaningful statement that illustrates your best attributes. Leaving a lasting impression on your reader is what will lead to interview invitations.

A quick note: if you are applying to schools that do not require the formal medical school personal statement, such as medical schools in Canada , you should still learn how to write such essays. Many medical schools in Ontario , for example, ask for short essays for supplementary questionnaires. These are very similar to the personal statement. Knowing how to brainstorm, write, and format your answers is key to your success!!!

You want to give yourself as much time as possible to write your statement. Do not think you can do this in an evening or even in a week. Some statements take months. My best statement took almost a year to get right. Allow yourself time and start early to avoid added stress. Think of the ideas you want to include and brainstorm possible ways to highlight these ideas. Ask your friends for ideas or even brainstorm your ideas with people you trust. Get some feedback early to make sure you are headed in the right direction.

“I wrote scores of essays at my desk in those few weeks leading up to application submission. I needed it to be perfect. Do not let anyone tell you to settle. There was no moment when I had this shining light from the sky filtering into my room to motivate me. The ultimate trick is to keep writing. It is impossible to get that perfect essay on the first try, and you may not even get it on your fifteenth attempt, but the goal is to keep at it, keep making those edits, and never back down.” – Dr. Vincent Adeyemi

All personal statements for medical school, often start by explaining why medicine is awesome; the admission committee already knows that. You should explain why you want a career in medicine. What is it about the practice of medicine that resonates with who you are? Naturally, this takes a lot of reflection around who you are. Here are some additional questions you can consider as you go about brainstorming for your essay:

• What motivates you to learn more about medicine?
• What is something you want them to know about you that isn't in your application?
• Where were you born, how did you grow up, and what type of childhood did you have growing up (perhaps including interesting stories about your siblings, parents, grandparents)?
• What kinds of early exposure to the medical field left an impression on you as a child?
• Did you become familiar with and interested in the field of medicine at an early stage of your life? If so, why?
• What are your key strengths, and how have you developed these?
• What steps did you take to familiarize yourself with the medical profession?
• Did you shadow a physician? Did you volunteer or work in a clinical setting? Did you get involved in medical research?
• What challenges have you faced? Have these made an impact on what you chose to study?
• What are your favorite activities?
• What kinds of extracurriculars for medical school or volunteer work have you done, and how have these shaped who you are, your priorities, and or your perspectives on a career in medicine?
• What was your "Aha!" moment?
• When did your desire to become a doctor solidify?
• How did you make the decision to apply to medical school?

You shouldn't try to answer all of these in your essay. Try only a few main points that will carry over into the final draft. Use these to brainstorm and gather ideas. Start developing your narrative by prioritizing the most impactful responses to these prompts and the ideas that are most relevant to your own experiences and goals. The perfect personal statement not only shows the admissions committee that you have refined communication skills, but also conveys maturity and professionalism. It should also display your motivation and suitability for medical practice. Here's how our student Alison, who was a non-traditional applicant with a serious red flag in her application, used her brainstorming sessions with our admissions experts to get a theme going in her medical school personal statement and her overall application package:

"I think it was during my brainstorming session that we really started talking about... what the theme [was] going to be for my application. And I think that was really helpful in and of itself. Just [reflecting] 'Hey, what's your focus going to be like? How are we going to write this? What's the style going to be?' Just to create an element of consistency throughout..." Alison, BeMo Student, current student at Dell Medical School 

After brainstorming, you should be able to clearly see a few key ideas, skills, qualities, and intersections that you want to write about. Once you've isolated the elements you want to explore in your essay (usually 2-4 key ideas), you can begin building your outline. In terms of structure, this should follow the standard academic format, with an introduction, body paragraphs, and a conclusion.

As you begin thinking about what to include in your personal essay, remember that you are writing for a specific audience with specific expectations. Your evaluator will be familiar with the key qualities desired by medical schools, as informed by the standards of the profession. But keep in mind that they too are human, and they respond well to well-crafted, engaging essays that tell a story. Here's what our student Alison had to share about keeping your audience in mind when writing your personal statement:

"Make it easy for the reader to be able to work [their] way through [your personal statement]. Because, at the end of the day, I think one thing that helped me a lot was being able to think about who was going to be reading this application and it's going to be these people that are sitting around a desk or sitting at a table and [go] through massive numbers of applications every single day. And the easier and more digestible that you can make it for them, gives you a little bit of a win." - Alison, BeMo student, current student at Dell Medical School

The admissions committee will be examining your essay through the lens of their particular school's mission, values, and priorities. You should think about your experiences with reference to the AAMC Core Competencies and to each school's mission statement so that you're working toward your narrative with the institution and broader discipline in mind.

Review AAMC Core Competencies : The AAMC Core Competencies are the key characteristics and skills sought by U.S. medical schools. These are separated into three general categories:

You are not expected to have mastered all of these competencies at this stage of your education. Display those that are relevant to your experiences will help demonstrate your commitment to the medical profession.

Review the school's mission statement: Educational institutions put a lot of time and care into drafting their school's vision. The mission statement will articulate the overall values and priorities of each university, giving you insight into what they might seek in candidates, and thus what you should try to display in your personal statement. Echoing the values of the university helps illustrate that you are a good fit for their intellectual culture. The mission statement may help you identify other priorities of the university, for example, whether they prioritize research-based or experiential-based education. All this research into your chosen medical schools will help you tremendously not only when you write you personal statement, but also the rest of your medical school application components, including your medical school letter of intent if you ever need to write one later.

Just like the personal statement is, in essence, a prompt without a prompt. They give you free rein to write your own prompt to tell your story. This is often difficult for students as they find it hard to get started without having a true direction. Below is a list of ideas to get your creative juices flowing. Use these prompts as a starting point for your essay. Also, they are a great way of addressing why you want to be a doctor without saying something generic.

• The moment your passion for medicine crystallized
• The events that led you toward this path
• Specific instances in which you experienced opportunities
• Challenges that helped shape your worldview
• Your compassion, resilience, or enthusiastic collaboration
• Demonstrate your commitment to others
• Your dependability
• Your leadership skills
• Your ability to problem-solve or to resolve a conflict

These are personal, impactful experiences that only you have had. Focus on the personal, and connect that to the values of your future profession. Do that and you will avoid writing the same essay as everyone else. Dr. Monica Taneja, MD and our admissions expert, shares her tip that got her accepted to the University of Maryland School of Medicine :

"I focused on my journey to medicine and opportunities that I sought out along the way. Everyone’s path and validation is unique, so walking the reader through your growth to the point of application will naturally be different, but that's what I wanted to share in my personal statement." - Dr. Monica Taneja, MD

“the essay is not about what you have been through; it's about who it made you into.” – dr. vincent adeyemi.

Admissions committees don't want your resumé in narrative form. The most boring essays are those of applicants listing their accomplishments. Remember, all that stuff is already in the activities section of the application. This is where you should discuss interesting or important life events that shaped you and your interest in medicine (a service trip to rural Guatemala, a death in the family, a personal experience as a patient). One suggestion is to have an overarching theme to your essay to tie everything together, starting with an anecdote. Alternatively, you can use one big metaphor or analogy through the essay. Dr. Jaime Cazes, MD and experienced admissions committee member of the University of Toronto Faculty of Medicine, encourages you to be creative when it comes to the theme of your personal statement:

"It is very easy to make the “cookie cutter” personal statement. To a reviewer who is reading tens of these at a time it can become quite boring. What I did was [tell] a story. Like any good novel, the stories' first lines are meant to hook the reader. This can be about anything if you can bring it back and relate it to your application. It could be about the time your friend was smashed up against the boards in hockey and you, with your limited first aid experience helped to treat him. It is important that the story be REAL." - Dr. Jaime Cazes, MD

Your personal statement must be well-organized, showing a clear, logical progression, as well as connections between ideas. It is generally best to use a chronological progression since this mirrors your progression into a mature adult and gives you the opportunity to illustrate how you learned from early mistakes later on. Carry the theme throughout the statement to achieve continuity and cohesion. Use the theme to links ideas from each paragraph to the next and to unite your piece.

Medical School Personal Statement Structure

When working toward the initial draft of your essay, it is important to keep the following in mind: The essay should read like a chronological narrative and have good structure and flow. Just like any academic essay, it will need an introduction, body content, and a conclusion. If you're wondering whether a medical school advisor can help you with your medical school application, check out our blog for the answer.

Check out our video to learn how to create a killer introduction to your medical school personal statement:

Introduction

The introductory paragraph and, even more importantly, the introductory sentence of your essay, will most certainly make or break your overall statement. Ensure that you have a creative and captivating opening sentence that draws the reader in. This is your first and only chance to make a first impression and really capture the attention of the committee. Starting with an event or an Aha! moment that inspired your decision to pursue a medical profession is one way to grab their attention. The kinds of things that inspire or motivate you can say a lot about who you are as a person.

The broader introductory paragraph itself should serve several functions. First, it must draw your reader in with an eye-catching first line and an engaging hook or anecdote. It should point toward the qualities that most effectively demonstrate your desire and suitability for becoming a physician (you will discuss these qualities further in the body paragraphs). The thesis of the introduction is that you have certain skills, experiences, and characteristics and that these skills, experiences, and characteristics will lead you to thrive in the field of medicine. Finally, it must also serve as a roadmap to the reader, allowing them to understand where the remainder of the story is headed.

That is a lot of work for a single paragraph to do. To better help you envision what this looks like in practice, here is a sample introduction that hits these main points.

I was convinced I was going to grow up to be a professional chef. This was not just another far-fetched idealistic childhood dream that many of us had growing up. There was a sense of certainty about this dream that motivated me to devote countless hours to its practice. It was mostly the wonder that it brought to others and the way they were left in awe after they tried a dish that I recall enjoying the most creating as a young chef. But, when I was 13, my grandfather was diagnosed with stage four lung cancer, and I realized that sometimes cooking is not enough, as I quickly learned about the vital role physicians play in the life of everyday people like my family and myself. Although my grandfather ended up passing away from his illness, the impact that the healthcare team had on him, my family, and I will always serve as the initial starting point of my fascination with the medical profession. Since that time, I have spent years learning more about the human sciences through my undergraduate studies and research, have developed a deeper understanding of the demands and challenges of the medical profession through my various volunteer and extra-curricular experiences, and although it has been difficult along the way, I have continued to forge a more intimate fascination with the medical field that has motivated me to apply to medical school at this juncture of my life. ","label":"Sample Introduction","title":"Sample Introduction"}]" code="tab3" template="BlogArticle">

In the body of your essay, you essentially want to elaborate on the ideas that you have introduced in your opening paragraph by drawing on your personal experiences to provide evidence. Major points from the above sample introduction could be: dedication and resilience (practicing cooking for hours, and devoting years to undergraduate studies in human sciences), passion and emotional connection (being able to create something that inspired awe in others, and personally connecting with the work of the grandfather's healthcare team), motivation and drive (being inspired by the role physicians play in their patients' lives, participating in volunteer work and extracurriculars, and an enduring fascination with the field of medicine). Depending on the details, a selection of volunteer and extra-curricular experiences might also be discussed in more detail, in order to emphasize other traits like collaboration, teamwork, perseverance, or a sense of social responsibility – all key characteristics sought by medical schools. Just like an academic essay, you will devote one paragraph to each major point, explaining this in detail, supporting your claims with experiences from your life, and reflecting on the meaning of each plot point in your personal narrative, with reference to why you want to pursue a medical career.

Your final statement should not be a simple summary of the things you have discussed. It should be insightful, captivating, and leave the reader with a lasting impression. Although you want to re-emphasize the major ideas of your essay, you should try to be creative and captivating, much like your opening paragraph. Sometimes if you can link your opening idea to your last paragraph it will really tie the whole essay together. The conclusion is just as important as the introduction. It is your last chance to express your medical aspirations. You want to impress the reader while also leaving them wanting more. In this case, more would mean getting an interview so they can learn more about who you are! Leave them thinking I have got to meet this person.

The narrative you construct should display some of your most tightly held values, principles, or ethical positions, along with key accomplishments and activities. If you see yourself as someone who is committed to community service, and you have a track record of such service, your story should feature this and provide insight into why you care about your community and what you learned from your experiences. Saying that you value community service when you've never volunteered a day in your life is pointless. Stating that your family is one where we support each other through challenge and loss (if this is indeed true), is excellent because it lays the groundwork for telling a story while showing that you are orientated towards close relationships. You would then go on to offer a brief anecdote that supports this. You are showing how you live such principles, rather than just telling your reader that you have such principles:

"Remember to use specific personal examples throughout your statement to make it more impactful and memorable for the readers. Often, painting a picture in the reader’s mind in the form of a story helps with this." - Dr. Neel Mistry, MD

A lot of students make the mistake of verbalizing their personal attributes with a bunch of adjectives, such as, "This experience taught me to be a self-reliant leader, with excellent communication skills, and empathy for others..." In reality, this does nothing to convey these qualities. It's a mistake to simply list your skills or characteristics without showing the reader an example of a time you used them to solve a problem. If you simply list your skills or characteristics (telling), without demonstrating the ways you have applied them (showing), you risk coming across as arrogant. The person reading the essay may not believe you, as you've not really given them a way to see such values in your actions. It is better to construct a narrative to show the reader that you possess the traits that medical schools are looking for, rather than explicitly stating that you are an empathetic individual or capable of deep self-reflection. Instead of listing adjectives, tell your personal story and allow the admissions committee to paint the picture for themselves. This step is very challenging for many students, but it's one of the most important strategies used in successful essays. Writing this way will absolutely make your statement stand out from the rest.

While it may be tempting to write in a high academic tone, using terminology or jargon that is often complex or discipline-specific, requiring a specialized vocabulary for comprehension. You should actually aim to write for a non-specialist audience. Remember, in the world of medicine, describing a complex, clinical condition to a patient requires using specific but clear words. This is why your personal statement should show that you can do the same thing. Using large words in unwieldy ways makes you sound like you are compensating for poor communication skills. Use words that you believe most people understand. Read your personal statement back to a 14-year-old, and then again to someone for whom English is not their first language, to see if you're on the right path.

Ultimately, fancy words do not make you a good communicator; listening and ensuring reader comprehension makes you a good communicator. Instead of using complex terminology to tell the admissions committee that you have strong communication skills, show them your communication skills through clear, accessible prose, written with non-specialists in mind. A common refrain among writing instructors is, never use a $10 word where a $2 word will suffice. If you can say it in plain, accessible language, then this is what you should do.

Display Professionalism

Professionalism may seem like a difficult quality to display when only composing a personal statement. After all, the reader can't see your mannerisms, your personal style, or any of those little qualities that allow someone to appear professional. Professionalism is about respect for the experience of others on your team or in your workplace. It is displayed when you are able to step back from your own individual position and think about what is best for your colleagues and peers, considering their needs alongside your own. If a story is relevant to why you want to be a physician and demonstrates an example of how you were professional in a workplace setting, then it is appropriate to include in your essay.

One easy way to destroy a sense of professionalism is to act in a judgmental way towards others, particularly if you perceived and ultimately resolved an error on someone else's part. Sometimes students blame another medical professional for something that went wrong with a patient.

They might say something to the effect of, "The nurse kept brushing off the patient's concerns, refusing to ask the attending to increase her pain medications. Luckily, being the empathetic individual that I am, I took the time to listen to sit with the patient, eventually bringing her concerns to the attending physician, who thanked me for letting him know."

There are a couple of things wrong with this example. It seems like this person is putting down someone else in an attempt to make themselves look better. They come across as un-empathetic and judgmental of the nurse. Maybe she was having a busy day, or maybe the attending had just seen the patient for this issue and the patient didn't really need re-assessment. Reading this kind of account in a personal statement makes the reader question the maturity of the applicant and their ability to move past blaming others and resolve problems in a meaningful way. Instead of allocating blame, identify what the problem was for the patient and then focus on what you did to resolve it and reflect on what you learned from the whole experience.

One last note on professionalism: Being professional does not mean being overly stoic, hiding your emotions, or cultivating a bland personality. A lot of students are afraid to talk about how a situation made them feel in their personal statement. They worry that discussing feelings is inappropriate and will appear unprofessional. Unfortunately for these students, emotional intelligence is hugely important to the practice of medicine. In order to be a good doctor, one must be aware of their own emotions as well as those of their patients. Good doctors are able to quickly identify their own emotions and understand how their emotional reactions may inform their actions, and the ability to deliver appropriate care, in a given situation. Someone who is incapable of identifying their emotions is also incapable of managing them effectively and will likely struggle to identify the emotions of others. So, when writing your personal statement, think about how each experience made you feel, and what you learned from those feelings and that experience.

How to Write About Discrepancies and Common Mistakes to Avoid

Part of your essay's body can include a discussion of any discrepancies or gaps in your education, or disruptions in your academic performance. If you had to take time off, or if you had a term or course with low grades, or if you had any other extenuating circumstances that impacted your education, you can take time to address these here. It is very important to address these strategically. Do not approach this section as space to plead your case. Offer a brief summary of the situation, and then emphasize what you learned from such hardships. Always focus on the positive, illustrating how such difficulties made you stronger, more resilient, or more compassionate. Connect your experiences to the qualities desired by medical schools. Here's how I student Alison address an academic discrepancy in her application:

I had an academic dishonesty during undergrad, which, at the time, ended up being this big misunderstanding. But I was going to appeal this and get it off my record. I was supposed to start nursing school two weeks after this whole ordeal had gone down and, at our university, if you try to appeal your academic dishonesty then you'd have to take an incomplete in that class and I needed this class in order to start nursing school. So I wasn't able to [appeal]. So when I talked with the people at the nursing school they were like ‘it's no big deal, it's fine’. [But] it came back and it haunted me very much. When I was applying [to medical school] I started looking online [to see] how big of a deal is it to have this ‘red flag’ on my application. I started reading all of these horror stories on Student Doctor Network and all of these other forums about how if you have an academic dishonesty you shouldn't even bother applying, that you'll never get in. Schools will blacklist you and I was [wondering] what am I going do. [My advisor suggested I use the essay to talk about my discrepancy]. 

First off, if anyone out there has an academic violation don't read student doctor network. don't listen to anybody. you absolutely are still a potential medical student and schools are not going to blacklist you just because of one mistake that you made. that's all lies. don't listen to them. i don't even think it came up a single time during any of my interviews. i think a lot of that came back to how i wrote that essay and the biggest advice that i can give that i got from the [bemo] team is explain what happened… just give the facts. be very objective about it. in the last two thirds [of the essay] you want to focus on what you learned from it and how it made you a better person and how it's going to make you a better physician.” – alison, bemo student, current student at dell medical school.

We hope many of you find a peace of mind when you read Alison's story. Because it shows that with the right approach to your medical school personal statement, you can overcome even red flags or setbacks that made you dread the application process. Use your personal statement to emphasize your ability to persevere through it all but do so in a positive way. Most of all, if you feel like you have to explain yourself, take accountability for the situation. State that it is unfortunate and then redirect it to what you learned and how it will make you a better doctor. Always focus on being positive and do not lament on the negative situation too much.

Additional Mistakes to Avoid in Personal Statements:

Check out this video on the top 5 errors to avoid in your personal statement!

Step 3: Writing Your First Draft

As you can see, there is a LOT of planning and consideration to be done before actually starting your first draft. Properly brainstorming, outlining, and considering the content and style of your essay prior to beginning the essay will make the writing process much smoother than it would be you to try to jump right to the draft-writing stage. Now, you're not just staring at a blank page wondering what you could possibly write to impress the admissions committee. Instead, you've researched what the school desires from its students and what the medical profession prioritizes in terms of personal characteristics, you've sketched out some key moments from your life that exemplify those traits, and you have a detailed outline that just needs filling in.

As you're getting started, focus on getting content on the page, filling in your outline and getting your ideas arranged on the page. Your essay will go through multiple drafts and re-writes, so the first step is to free write and start articulating connections between your experiences and the characteristics you're highlighting. You can worry about flow, transitions, and perfect grammar in later drafts. The first draft is always a working draft, written with the understanding that its purpose is to act as a starting point, not an ending point. Once you've completed a draft, you can begin the revising process. The next section will break down what to do once you have your first draft completed.

You can also begin looking at things like style, voice, transitions, and overall theme. The best way to do this is to read your essay aloud. This may sound strange, but it is one of the single most impactful bits of writing advice a student can receive. When we're reading in our heads (and particularly when we're reading our own words), it is easy to skip over parts that may be awkwardly worded, or where the grammar is off. As our brains process information differently, depending on whether we're taking in visual or auditory information, this can also help you understand where the connections between ideas aren't as evident as you would like. Reading the essay aloud will help you begin internalizing the narrative you've crafted, so that you can come to more easily express this both formally in writing and informally in conversation (for example, in an interview).

#1 Did You Distinguish Yourself From Others?

Does your narrative sound unique? Is it different than your peers or did you write in a generic manner? Our admissions expert Dr. Monica Taneja, MD, shares how she got the attention of the admissions committee with her personal statement:

"I also found it helpful to give schools a 'punch-line'. As in I wanted them to remember 1-2 things about me that are my differentiators and I reiterated those throughout [the personal statement]." - Dr. Monica Taneja, MD

Use your narrative to provide a compelling picture of who you are as a person, as a learner, as an advocate, and as a future medical professional. What can you offer? Remember, you will be getting a lot out of your med school experience, but the school will be getting a lot out of you, as well. You will be contributing your research efforts to your department, you will be participating in the academic community, and as you go on to become a successful medical professional you will impact the perception of your school's prestige. This is a mutually beneficial relationship, so use this opportunity to highlight what you bring to the table, and what you will contribute as a student at their institution. Let them know what it is about you that is an attribute to their program. Make them see you as a stand out from the crowd.

#2 Does My Essay Flow and is it Comprehensible?

Personal statements are a blessing and a curse for admission committees. They give them a better glimpse of who the applicant is than simple scores. Also, they are long and time-consuming to read. And often, they sound exactly alike. On occasion, a personal statement really makes an applicant shine. After reading page after page of redundant, cookie-cutter essays, an essay comes along with fluid prose and a compelling narrative, the reader snaps out of that feeling of monotony and gladly extends their enthusiastic attention.

Frankly, if the statement is pleasant to read, it will get read with more attention and appreciation. Flow is easier to craft through narrative, which is why you should root the statement in a story that demonstrates characteristics desirable to medical schools. Fluidity takes time to build, though, so your statement should be etched out through many drafts and should also be based on an outline. You need to brainstorm, then outline, then draft and re-draft, and then bring in editors and listeners for feedback (Note: You need someone to proofread your work. Bestselling authors have editors. Top scholars have editors. I need an editor. You need an editor. Everyone needs an editor). Then, check and double-check and fix anything that needs fixing. Then check again. Then submit. You want this to be a statement that captures the reader's interest by creating a fluid, comprehensible piece that leads the reader to not only read each paragraph but want to continue to the next sentence.

#3 Did You Check Your Grammar?

If you give yourself more than one night to write your statement, the chances of grammatical errors will decrease considerably. If you are pressed for time, upload your file into an online grammar website. Use the grammar checker on your word processor, but know that this, in itself, isn't enough. Use the eyes and ears of other people to check and double-check your grammar, punctuation, and syntax. Read your statement out loud to yourself and you will almost certainly find an error (and likely several errors). Use fresh eyes to review the statement several times before you actually submit it, by walking away from it for a day or so and then re-reading it. Start your essay early, so that you actually have time to do this. This step can make or break your essay. Do not waste all the effort you have put into writing, to only be discarded by the committee for using incorrect grammar and syntax.

#4 Did You Gather Feedback From Other People?

The most important tip in writing a strong application essay is this getting someone else to read your work. While the tips above are all very useful for writing a strong draft, nothing will benefit you more than getting an outside appraisal of your work. For example, it's very easy to overlook your own spelling or grammatical errors. You know your own story and you may think that your narrative and it's meaning make sense to your reader. You won't know that for sure without having someone else actually read it. This may sound obvious, but it's still an absolute necessity.

“It was very helpful for two of my mentors to review my statements before submitting my application. Ensure you trust the judgement and skills of the person to whom you would be giving your personal statement for review.” – Dr. Vincent Adeyemi

Have someone you trust to read the essay and ask them what they thought of it. What was their impression of you after reading it? Did it make sense? Was it confusing? Do they have any questions? What was the tone of the essay? Do they see the connections you're trying to make? What were their takeaways from your essay, and do these align with your intended takeaways for your reader? Ideally, this person should have some knowledge of the application process or the medical profession, so that they can say whether you were successful in demonstrating that you are a suitable candidate for medical school. However, any external reader is better than no external reader at all.

Avoid having people too close to you read your work. They may refrain from being too critical in an effort to spare your feelings. This is the time to get brutal, honest feedback. If you know someone who is an editor but do not feel that they can be objective, try and find someone else.

Want more examples? Check out our video below:

FAQs and Final Notes

Your personal statement should tell your story and highlight specific experiences or aspects of your journey that have led you to medicine. If your first exposure or interest in the medical field was sparked from your own medical struggles, then you can certainly include this in your statement. What is most important is that you write about what factors or experiences attributed to you deciding that medicine is the right career path for you.

Sometimes students shy away from including their own personal struggles and describing how they felt during difficult times but this is a great way for admissions committees to gain perspective into who you are as a person and where your motivations lie. Remember, this is your story, not someone else's, so your statement should revolve around you. If you choose to discuss a personal hardship, what's most important is that you don't cast yourself as the victim and that you discuss what the experience taught you. Also, medical schools are not allowed to discriminate against students for discussing medical issues, so it is not looked at as a red flag unless you are talking about an issue inappropriately. For example, making yourself appear as the victim or not taking responsibility.

All US medical schools require the completion of a personal statement with your AMCAS, TMDSAS or AACOMAS applications.

Medical schools in Canada on the other hand, do not require or accept personal statements. In lieu of the personal statement, a few of these schools may require you to address a prompt in the form of an essay, or allow you to submit an explanation essay to describe any extenuating circumstances, but this is not the same as the US personal statement. For example, when applying through  OMSAS , the  University of Toronto medical school  requires applicants to complete four short, 250 words or less, personal essays.

Many students struggle with whether or not they should address an unfavorable grade in their personal statement. What one student does isn't necessarily the right decision for you.

To help you decide, think about whether or not that bad grade might reflect on your poorly. If you think it will, then it's best to address the academic misstep head-on instead of having admissions committees dwell on possible areas of concern. If you're addressing a poor evaluation, ensure that you take responsibility for your grade, discuss what you learned and how your performance will be improved in the future - then move on. It's important that you don't play the victim and you must always reflect on what lessons you've learned moving forward.

Of course not, just because you didn't wake up one morning and notice a lightbulb flashing the words medicine, doesn't mean that your experiences and journey to medicine are inferior to those who did. Students arrive to medicine in all sorts of ways, some change career paths later in life, some always knew they wanted to pursue medicine, and others slowly became interested in medicine through their life interactions and experiences. Your personal statement should address your own unique story to how you first became interested in medicine and when and how that interest turned to a concrete desire.

While your entire statement is important, the opening sentence can often make or break your statement. This is because admission committee members are reviewing hundreds, if not thousands of personal statements. If your opening sentence is not eye-catching, interesting, and memorable, you risk your statement blending in with the large pile of other statements. Have a look at our video above for tips and strategies for creating a fantastic opening sentence.

Having your statement reviewed by family and friends can be a good place to start, but unfortunately, it's near-impossible for them to provide you with unbiased feedback. Often, friends and family members are going to support us and rave about our achievements. Even if they may truly think your statement needs work, they may feel uncomfortable giving you their honest feedback at the risk of hurting your feelings.

In addition, family and friends don't know exactly what admission committee members are looking for in a personal statement, nor do they have years of experience reviewing personal statements and helping students put the best version of themselves forward. For these reasons, many students choose to seek the help of a professional medical school advisor to make sure they have the absolute best chances of acceptance to medical school the first time around.

If you have enough time set aside to write your statement without juggling multiple other commitments, it normally takes at least four weeks to write your statement. If you are working, in school, or volunteering and have other commitments, be prepared to spend 6-8 weeks.

Your conclusion should have a summary of the main points you have made in your essay, but it should not just be a summary. You should also end with something that makes the reader want to learn more about you (i.e. call you for an interview). A good way to do this is to include a call-back to your opening anecdote: how have you grown or matured since then? How are you more prepared now to begin medical school?

The goal is to show as many of them as you can in the WHOLE application: this includes your personal statement, sketch, reference letters, secondary essays, and even your GPA and MCAT (which show critical thinking and reasoning already). So, it’s not an issue to focus on only a few select experiences and competencies in the personal statement.

Yes, you can. However, if you used an experience as a most meaningful entry, pick something else to talk about in your essay. Remember, you want to highlight as many core competencies across your whole application). Or, if you do pick the same experience: pick a different specific encounter or project with a different lesson learned.

Once your essay is in good shape, it's best to submit to ensure your application is reviewed as soon as possible. Remember, with rolling admissions, as more time passes before you submit your application, your chances of acceptance decreases. Nerves are normal and wanting to tinker is also normal, but over-analyzing and constant adjustments can actually weaken your essay.

So, if you're thinking about making more changes, it's important to really reflect and think about WHY you want to change something and if it will actually make the essay stronger. If not your changes won't actually make the essay stronger or if it's a very minor change you're thinking of making, then you should likely leave it as is.

The reality is, medical school admission is an extremely competitive process. In order to have the best chance of success, every part of your application must be stellar. Also, every year some students get in whose GPAs or  MCAT scores  are below the median. How? Simply because they must have stood out in other parts of the application, such as the personal statement.

The ones that honestly made the most impact on you. You'll need to reflect on your whole life and think about which experiences helped you grow and pushed you to pursue medicine. Ideally, experiences that show commitment and progression are better than one-off or short-term activities, as they usually contribute more to growth.

Final Notes

This Ultimate Guide has demonstrated all the work that needs to be done to compose a successful, engaging personal statement for your medical school application. While it would be wonderful if there was an easy way to write your personal statement in a day, the reality is that this kind of composition takes a lot of work. As daunting as this may seem, this guide lays out a clear path. In summary, the following 5 steps are the basis of what you should take away from this guide. These 5 steps are your guide and sort of cheat sheet to writing your best personal statement.

5 Main Takeaways For Personal Statement Writing:

• Brainstorming
• Content and Theme
• Multiple Drafts
• Revision With Attention to Grammar

While a strong personal statement alone will not guarantee admission to medical school, it could absolutely squeeze you onto a  medical school waitlist , off the waitlist, and onto the offer list, or give someone on the admissions committee a reason to go to battle for your candidacy. Use this as an opportunity to highlight the incredible skills you've worked and studied to refine, the remarkable life experiences you've had, and the key qualities you possess in your own unique way. Show the admissions committee that you are someone they want to meet. Remember, in this context, wanting to meet you means wanting to bring you in for an interview!

Dr. Lauren Prufer is an admissions expert at BeMo. Dr. Prufer is also a medical resident at McMaster University. Her medical degree is from the Schulich School of Medicine and Dentistry. During her time in medical school, she developed a passion for sharing her knowledge with others through medical writing, research, and peer mentoring.

To your success,

Your friends at BeMo

BeMo Academic Consulting

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Great Medical School Personal Statement Examples (2024-2025) Insider’s Guide

A physician and former medical school admissions officer teaches you how to write your medical school personal statement, step by step. Read several full-length medical school personal statement examples for inspiration.

In this article, a former medical school admissions officer explains exactly how to write a stand-out medical school personal statement!

Our goal is to empower you to write a medical school personal statement that reflects your individuality, truest aspirations and genuine motivations.

This guide also includes:

• Real life medical school personal statement examples
• Medical school personal statement inventory template and outline exercise
• AMCAS, TMDSAS, and AACOMAS personal statement prompts
• Advanced strategies to ensure you address everything admissions committees want to know
• The secret to writing a great medical school personal statement

So, if you want your medical school personal statement to earn more more medical school interviews, you will love this informative guide.

Let’s dive right in.

Table of Contents

Medical School Personal Statement Fundamentals

If you are getting ready to write your medical school personal statement for the 2024-2025 application year, you may already know that almost 60% of medical school applicants are not accepted every year . You have most likely also completed all of your medical school requirements and have scoured the internet for worthy medical school personal statement examples and guidance.

You know the medical school personal statement offers a crucial opportunity to show medical schools who you are beyond your GPA and MCAT score .

It provides an opportunity to express who you are as an individual, the major influences and background that have shaped your interests and values, what inspired you to pursue medicine, and what kind of a physician you envision yourself becoming.

However, with so much information online, you are not sure who to trust. We are happy you have found us!

Because the vast majority of people offering guidance are not former admissions officers or doctors , you must be careful when searching online.

We are real medical school admissions insiders and know what goes on behind closed doors and how to ensure your medical school personal statement has broad appeal while highlighting your most crucial accomplishments, perspectives, and insights.

With tight limits on space, it can be tough trying to decide what to include in your medical school personal statement to make sure you stand out. You must think strategically about how you want to present your personal “big picture” while showing you possess the preprofessional competencies med schools are seeking.

When a medical school admissions reviewer finishes reading your medical school personal statement, ask yourself:

• What are the most important things you want that person to remember about you?
• Does your medical school personal statement sum up your personality, interests, and talents?
• Does your medical school personal statement sound as if it’s written from the heart?

It’s pretty obvious to most admissions reviewers when applicants are trying too hard to impress them. Being authentic and upfront about who you are is the best way to be a memorable applicant.

The Biggest Medical School Personal Statement Mistakes

The most common medical school personal statement mistake we see students make is that they write about:

• What they have accomplished
• How they have accomplished it

By including details on what you have accomplished and how, you will make yourself sound like every other medical school applicant. 

Most medical school applicants are involved in similar activities: research, clinical work, service, and social justice work. 

To stand out, you must write from the heart making it clear you haven’t marched through your premedical years and checking boxes.

We also strongly discourage applicants from using ChatGPT or any AI bot to write their medical school personal statement. Writing in your own voice is essential and using anything automated will undermine success.

The Medical School Personal Statement Secret

MedEdits students stand out in the medical school personal statement because in their personal statements they address:

WHY they have accomplished what they have.

In other words, they write in more detail about their passions, interests, and what is genuinely important to them. 

It sounds simple, we know, but by writing in a natural way, really zeroing in on WHY YOU DO WHAT YOU DO, you will appeal to a wide variety of people in a humanistic way. 

MedEdits students have done extremely well in the most recent medical school admissions cycle. Many of these applicants have below average “stats” for the medical schools from which they are receiving interviews and acceptances.

Why? How is that possible? They all have a few things in common:

• They write a narrative that is authentic and distinctive to them.
• They write a medical school personal statement with broad appeal (many different types of people will be evaluating your application; most are not physicians).
• They don’t try too hard to impress; instead they write about the most impactful experiences they have had on their path to medical school.
• They demonstrate they are humble, intellectual, compassionate, and committed to a career in medicine all at the same time.

Keep reading for a step by step approach to write your medical school personal statement.

“After sitting on a medical school admissions committee for many years, I can tell you, think strategically about how you want to present your personal “big picture.” We want to know who you are as a human being.”

As physicians, former medical school faculty, and medical school admissions committee members, this article will offer a step by step guide to simplify the medical school personal statement brainstorming and writing process.

By following the proven strategies outlined in this article, you will be and to write a personal statement that will earn you more medical school interviews . This proven approach has helped hundreds of medical school applicants get in to medical school the first time they apply!

Learn the 2024-2025 Medical School Personal Statement Prompts ( AMCAS , TMDSAS , AACOMAS )

The personal statement is the major essay portion of your primary application process. In it, you should describe yourself and your background, as well as any important early exposures to medicine, how and why medicine first piqued your interest, what you have done as a pre med, your personal experiences, and how you became increasingly fascinated with it. It’s also key to explain why medicine is the right career for you, in terms of both personal and intellectual fulfillment, and to show your commitment has continued to deepen as you learned more about the field.

The personal statement also offers you the opportunity to express who you are outside of medicine. What are your other interests? Where did you grow up? What did you enjoy about college? Figuring out what aspects of your background to highlight is important since this is one of your only chances to express to the med school admissions committee before your interview what is important to you and why.

However, it is important to consider the actual personal statement prompt for each system through which you will apply, AMCAS, AACOMAS, and TMDSAS, since each is slightly different.

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2024 AMCAS Personal Statement Prompt

The AMCAS personal statement instructions are as follows:

Use the Personal Comments Essay as an opportunity to distinguish yourself from other applicants. Consider and write your Personal Comments Essay carefully; many admissions committees place significant weight on the essay. Here are some questions that you may want to consider while writing the essay:

• Why have you selected the field of medicine?
• What motivates you to learn more about medicine?
• What do you want medical schools to know about you that hasn’t been disclosed in other sections of the application?

In addition, you may wish to include information such as:

• Unique hardships, challenges, or obstacles that may have influenced your educational pursuits
• Comments on significant fluctuations in your academic record that are not explained elsewhere in your application

As you can see, these prompts are not vague; there are fundamental questions that admissions committees want you to answer when writing your personal statement. While the content of your statement should be focused on medicine, answering the open ended third question is a bit trickier.

The AMCAS personal statement length is 5,300 characters with spaces maximum.

2024 TMDSAS Personal Statement Prompt

The TMDSAS personal statement is one of the most important pieces of your medical school application.

The TMDSAS personal statement prompt is as follows:

Explain your motivation to seek a career in medicine. Be sure to include the value of your experiences that prepare you to be a physician.

This TMDSAS prompt is very similar to the AMCAS personal statement prompt. The TMDSAS personal statement length is 5,000 characters with spaces whereas the AMCAS personal statement length is 5,300 characters with spaces. Most students use the same essay (with very minor modifications, if necessary) for both application systems.

You’ve been working hard on your med school application, reading medical school personal statement examples, editing, revising, editing and revising.  Make sure you know where you’re sending your personal statement and application.  Watch this important medical school admissions statistics video.

2024 AACOMAS Personal Statement Prompt

The AACOMAS personal statement is for osteopathic medical schools specifically. As with the AMCAS statement, you need to lay out your journey to medicine as chronologically as possible in 5,300 characters with spaces or less. So you essentially have the same story map as for an AMCAS statement. Most important, you must show you are interested in osteopathy specifically. Therefore, when trying to decide what to include or leave out, prioritize any osteopathy experiences you have had, or those that are in line with the osteopathic philosophy of the mind-body connection, the body as self-healing, and other tenets.

Medical School Application Timeline and When to Write your Personal Statement

If you’re applying to both allopathic and osteopathic schools, you can most likely use the same medical school personal statement for both AMCAS and AACOMAS. In fact, this is why AACOMAS changed the personal statement length to match the AMCAS length several years ago.

Most medical school personal statements can be used for AMCAS and AACOMAS.

Know the Required Medical School Personal Statement Length

Below are the medical schools personal statement length limits for each application system. As you can see, they are all very similar. When you start brainstorming and writing your personal statement, keep these limits in mind.

AMCAS Personal Statement Length : 5,300 characters with spaces.

As per the AAMC website :   “The available space for this essay is 5,300 characters (spaces are counted as characters), or approximately one page. You will receive an error message if you exceed the available space.”

AACOMAS Personal Statement Length : 5,300 characters with spaces

TMDSAS Personal Statement Length : 5,000 characters with spaces

As per the TMDSAS Website (Page 36): “The personal essay asks you to explain your motivation to seek a career in medicine. You are asked to include the value of your experiences that prepare you to be a physician. The essay is limited to 5000 characters, including spaces.”

Demonstrate Required Preprofessional Competencies

Next, your want to be aware of the nine preprofessional core competencies as outlined by the Association of American Medical Colleges . Medical school admissions committees want to see, as evidenced by your medical school personal statement and application, that you possess these qualities and characteristics. Now, don’t worry, medical school admissions committees don’t expect you to demonstrate all of them, but, you should demonstrate some.

• Service Orientation
• Social Skills
• Cultural Competence
• Oral Communication
• Ethical Responsibility to Self and Others
• Reliability and Dependability
• Resilience and Adaptability
• Capacity for Improvement

In your personal statement, you might be able to also demonstrate the four thinking and reasoning competencies:

• Critical Thinking
• Quantitative Reasoning
• Written Communication
• Scientific Inquiry

So, let’s think about how to address the personal statement prompts in a slightly different way while ensuring you demonstrate the preprofessional competencies. When writing your personal statement, be sure it answers the four questions that follow and you will “hit” most of the core competencies listed above.

1. What have you done that supports your interest in becoming a doctor?

I always advise applicants to practice “evidence based admissions.” The reader of your essay wants to see the “evidence” that you have done what is necessary to understand the practice of medicine. This includes clinical exposure, research, and community service, among other activities.

2. Why do you want to be a doctor?

This may seem pretty basic – and it is – but admissions officers need to know WHY you want to practice medicine. Many applicants make the mistake of simply listing what they have done without offering insights about those experiences that answer the question, “Why medicine?” Your reasons for wanting to be a doctor may overlap with those of other applicants. This is okay because the experiences in which you participated, the stories you can tell about those experiences, and the wisdom you gained are completely distinct—because they are only yours. 

“In admissions committee meetings we were always interested in WHY you wanted to earn a medical degree and how you would contribute to the medical school community.”

Medical school admissions committees want to know that you have explored your interest deeply and that you can reflect on the significance of these clinical experiences and volunteer work. But writing only that you “want to help people” does not support a sincere desire to become a physician; you must indicate why the medical profession in particular—rather than social work, teaching, or another “helping” profession—is your goal. 

3. How have your experiences influenced you?

It is important to show how your experiences are linked and how they have influenced you. How did your experiences motivate you? How did they affect what else you did in your life? How did your experiences shape your future goals? Medical school admissions committees like to see a sensible progression of involvements. While not every activity needs to be logically “connected” with another, the evolution of your interests and how your experiences have nurtured your future goals and ambitions show that you are motivated and committed.

4. Who are you as a person? What are your values and ideals?

Medical school admissions committees want to know about you as an individual beyond your interests in medicine, too. This is where answering that third open ended question in the prompt becomes so important. What was interesting about your background, youth, and home life? What did you enjoy most about college? Do you have any distinctive passions or interests? They want to be convinced that you are a good person beyond your experiences. Write about those topics that are unlikely to appear elsewhere in your statement that will offer depth and interest to your work and illustrate the qualities and characteristics you possess.

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Complete Your Personal Inventory and Outline (Example Below)

The bulk of your essay should be about your most valuable experiences, personal, academic, scholarly, clinical, academic and extracurricular activities that have impacted your path to medical school and through which you have learned about the practice of medicine. The best personal statements cover several topics and are not narrow in scope. Why is this important? Many different people with a variety of backgrounds, interests, and ideas of what makes a great medical student will be reading your essay. You want to make sure you essay has broad appeal.

The following exercise will help you to determine what experiences you should highlight in your personal statement. 

When composing your personal statement, keep in mind that you are writing, in effect, a “story” of how you arrived at this point in your life. But, unlike a “story” in the creative sense, yours must also offer convincing evidence for your decision to apply to medical school. Before starting your personal statement, create an experience- based personal inventory:

• Write down a list of the most important experiences in your life and your development. The list should be all inclusive and comprise those experiences that had the most impact on you. Put the list, which should consist of personal, extracurricular, and academic events, in chronological order.
• From this list, determine which experiences you consider the most important in helping you decide to pursue a career in medicine. This “experience oriented” approach will allow you to determine which experiences best illustrate the personal competencies admissions committees look for in your written documents. Remember that you must provide evidence for your interest in medicine and for most of the personal qualities and characteristics that medical school admissions committees want to see.
• After making your list, think about why each “most important” experience was influential and write that down. What did you observe? What did you learn? What insights did you gain? How  did the experience influence your path and choices?
• Then think of a story or illustration for why each experience was important.
• After doing this exercise, evaluate each experience for its significance and influence and for its “story” value. Choose to write about those experiences that not only were influential but that also will provide interesting reading, keeping in mind that  your goal is to weave the pertinent experiences together into a compelling story. In making your choices, think about how you will link each experience and transition from one topic to the next.
• Decide which of your listed experiences you will use for your introduction first (see below for more about your introduction). Then decide which experiences you will include in the body of your personal statement, create a general outline, and get writing!

Remember, you will also have your work and activities entries and your secondary applications to write in more detail about your experiences. Therefore, don’t feel you must pack everything in to your statement!

Craft a Compelling Personal Statement Introduction and Body

You hear conflicting advice about application essays. Some tell you not to open with a story. Others tell you to always begin with a story. Regardless of the advice you receive, be sure to do three things:

• Be true to yourself. Everyone will have an opinion regarding what you should and should not write. Follow your own instincts. Your personal statement should be a reflection of you, and only you.
• Start your personal statement with something catchy.  Think about the list of potential topics above.
• Don’t rush your work. Composing thoughtful documents takes time and you don’t want your writing and ideas to be sloppy and underdeveloped.

Most important is to begin with something that engages your reader. A narrative, a “story,” an anecdote written in the first or third person, is ideal. Whatever your approach, your first paragraph must grab your reader’s attention and motivate him to want to continue reading. I encourage applicants to start their personal statement by describing an experience that was especially influential in setting them on their path to medical school. This can be a personal or scholarly experience or an extracurricular one. Remember to avoid clichés and quotes and to be honest and authentic in your writing. Don’t try to be someone who you are not by trying to imitate personal statement examples you have read online or “tell them what you think they want to hear”; consistency is key and your interviewer is going to make sure that you are who you say you are!

When deciding what experiences to include in the body of your personal statement, go back to your personal inventory and identify those experiences that have been the most influential in your personal path and your path to medical school. Keep in mind that the reader wants to have an idea of who you are as a human being so don’t write your personal statement as a glorified resume. Include some information about your background and personal experiences that can give a picture of who you are as a person outside of the classroom or laboratory.

Ideally, you should choose two or three experiences to highlight in the body of your personal statement. You don’t want to write about all of your accomplishments; that is what your application entries are for!

Write Your Personal Statement Conclusion

In your conclusion, it is customary to “go full circle” by coming back to the topic—or anecdote—you introduced in the introduction, but this is not a must. Summarize why you want to be a doctor and address what you hope to achieve and your goals for medical school. Write a conclusion that is compelling and will leave the reader wanting to meet you.

Complete Personal Statement Checklist

When reading your medical school personal statement be sure it:

Shows insight and introspection

The best medical school personal statements tell a great deal about what you have learned through your experiences and the insights you have gained.

You want to tell your story by highlighting those experiences that have been the most influential on your path to medical school and to give a clear sense of chronology. You want your statement always to be logical and never to confuse your reader.

Is interesting and engaging

The best personal statements engage the reader. This doesn’t mean you must use big words or be a literary prize winner. Write in your own language and voice, but really think about your journey to medical school and the most intriguing experiences you have had.

Gives the reader a mental image of who you are

You want the reader to be able to envision you as a caregiver and a medical professional. You want to convey that you would be a compassionate provider at the bedside – someone who could cope well with crisis and adversity.

Illustrates your passion for, and commitment to, medicine

Your reader must be convinced that you are excited about and committed to a career in medicine!

Above all, your personal statement should be about you. Explain to your reader what you have done and why you want to be a doctor with insight, compassion, and understanding.

Medical School Personal Statement Myths

Also keep in mind some common myths about personal statements that I hear quite often:

My personal statement must have a theme.

Not true. The vast majority of personal statements do not have themes. In fact, most are somewhat autobiographical and are just as interesting as those statements that are woven around a “theme.” It is only the very talented writer who can creatively write a personal statement around a theme, and this approach often backfires since the applicant fails to answer the three questions above.

My personal statement must be no longer than one page.

Not true. This advice is antiquated and dates back to the days of the written application when admissions committees flipped through pages. If your personal statement is interesting and compelling, it is fine to use the entire allotted space. The application systems have incorporated limits for exactly this reason! Many students, depending on their unique circumstances, can actually undermine their success by limiting their personal statement to a page. That said, never max out a space just for the sake of doing so. Quality writing and perspectives are preferable to quantity.

My personal statement should not describe patient encounters or my personal medical experiences.

Not true. Again, the actual topics on which you focus in your personal statement are less important than the understanding you gained from those experiences. I have successful clients who have written extremely powerful and compelling personal statements that included information about clinical encounters – both personal and professional. Write about whichever experiences were the most important on your path to medicine. It’s always best, however, to avoid spending too much space on childhood and high school activities. Focus instead on those that are more current.

In my personal statement I need to sell myself.

Not exactly true. You never want to boast in your personal statement. Let your experiences, insights, and observations speak for themselves. You want your reader to draw the conclusion – on his or her own – that you have the qualities and characteristics the medical school seeks. Never tell what qualities and characteristics you possess; let readers draw these conclusions on their own based on what you write.

Medical School Personal Statement Examples and Analysis for Inspiration

Below are examples of actual medical school personal statements. You can also likely find medical school personal statements on Reddit.

AMCAS Medical School Personal Statement Example and Analysis #1 with Personal Inventory  

We will use Amy to illustrate the general process of writing an application to medical school, along with providing the resulting documents. Amy will first list those experiences, personal, extracurricular, and scholarly, that have been most influential in two areas: her life in general and her path to medical school. She will put this personal inventory in chronologic order for use in composing her personal statement.

She will then select those experiences that were the most significant to her and will reflect and think about why they were important. For her application entries, Amy will write about each experience, including those that she considers influential in her life but not in her choice of medicine, in her application entries. Experiences that Amy will not write about in her activity entries or her personal statement are those that she does not consider most influential in either her life or in her choice of medicine.

Amy’s personal inventory (from oldest to most recent)

• Going with my mom to work. She is a surgeon — I was very curious about what she did. I was intrigued by the relationships she had with patients and how much they valued her efforts. I also loved seeing her as “a doctor” since, to me, she was just “mom.”
• I loved biology in high school. I started to think seriously about medicine then. It was during high school that I became fascinated with biology and how the human body worked. I would say that was when I thought, “Hmm, maybe I should be a doctor.”
• Grandmother’s death, senior year of high school. My grandmother’s death was tragic. It was the first time I had ever seen someone close to me suffer. It was one of the most devastating experiences in my life.
• Global Health Trip to Guatemala my freshman year of college. I realized after going to Guatemala that I had always taken my access to health care for granted. Here I saw children who didn’t have basic health care. This made me want to become a physician so I could give more to people like those I met in Guatemala.
• Sorority involvement. Even though sorority life might seem trivial, I loved it. I learned to work with different types of people and gained some really valuable leadership experience.
• Poor grades in college science classes. I still regret that I did badly in my science classes. I think I was immature and was also too involved in other activities and didn’t have the focus I needed to do well. I had a 3.4 undergraduate GPA.
• Teaching and tutoring Jose, a child from Honduras. In a way, meeting Jose in a college tutoring program brought my Guatemala experience to my home. Jose struggled academically, and his parents were immigrants and spoke only Spanish, so they had their own challenges. I tried to help Jose as much as I could. I saw that because he lacked resources, he was at a tremendous disadvantage.
• Volunteering at Excellent Medical Center. Shadowing physicians at the medical center gave me a really broad view of medicine. I learned about different specialties, met many different patients, and saw both great and not-so-great physician role models. Counselor at Ronald McDonald House. Working with sick kids made me appreciate my health. I tried to make them happy and was so impressed with their resilience. It made me realize that good health is everything.
• Oncology research. Understanding what happens behind the scenes in research was fascinating. Not only did I gain some valuable research experience, but I learned how research is done.
• Peer health counselor. Communicating with my peers about really important medical tests gave me an idea of the tremendous responsibility that doctors have. I also learned that it is important to be sensitive, to listen, and to be open-minded when working with others.
• Clinical Summer Program. This gave me an entirely new view of medicine. I worked with the forensics department, and visiting scenes of deaths was entirely new to me. This experience added a completely new dimension to my understanding of medicine and how illness and death affect loved ones.
• Emergency department internship. Here I learned so much about how things worked in the hospital. I realized how important it was that people who worked in the clinical department were involved in creating hospital policies. This made me understand, in practical terms, how an MPH would give me the foundation to make even more change in the future.
• Master’s in public health. I decided to get an MPH for two reasons. First of all, I knew my undergraduate science GPA was an issue so I figured that graduate level courses in which I performed well would boost my record. I don’t think I will write this on my application, but I also thought the degree would give me other skills if I didn’t get into medical school, and I knew it would also give me something on which I could build during medical school and in my career since I was interested in policy work.

As you can see from Amy’s personal inventory list, she has many accomplishments that are important to her and influenced her path. The most influential personal experience that motivated her to practice medicine was her mother’s career as a practicing physician, but Amy was also motivated by watching her mother’s career evolve. Even though the death of her grandmother was devastating for Amy, she did not consider this experience especially influential in her choice to attend medical school so she didn’t write about it in her personal statement.

Amy wrote an experience-based personal statement, rich with anecdotes and detailed descriptions, to illustrate the evolution of her interest in medicine and how this motivated her to also earn a master’s in public health.

Amy’s Medical School Personal Statement Example:

She was sprawled across the floor of her apartment. Scattered trash, decaying food, alcohol bottles, medication vials, and cigarette butts covered the floor. I had just graduated from college, and this was my first day on rotation with the forensic pathology department as a Summer Scholar, one of my most valuable activities on the path to medical school. As the coroner deputy scanned the scene for clues to what caused this woman’s death, I saw her distraught husband. I did not know what to say other than “I am so sorry.” I listened intently as he repeated the same stories about his wife and his dismay that he never got to say goodbye. The next day, alongside the coroner as he performed the autopsy, I could not stop thinking about the grieving man.

Discerning a cause of death was not something I had previously associated with the practice of medicine. As a child, I often spent Saturday mornings with my mother, a surgeon, as she rounded on patients. I witnessed the results of her actions, as she provided her patients a renewed chance at life. I grew to honor and respect my mother’s profession. Witnessing the immense gratitude of her patients and their families, I quickly came to admire the impact she was able to make in the lives of her patients and their loved ones.

I knew I wanted to pursue a career in medicine as my mother had, and throughout high school and college I sought out clinical, research, and volunteer opportunities to gain a deeper understanding of medicine. After volunteering with cancer survivors at Camp Ronald McDonald, I was inspired to further understand this disease. Through my oncology research, I learned about therapeutic processes for treatment development. Further, following my experience administering HIV tests, I completed research on point-of-care HIV testing, to be instituted throughout 26 hospitals and clinics. I realized that research often served as a basis for change in policy and medical practice and sought out opportunities to learn more about both.

All of my medically related experiences demonstrated that people who were ‘behind the scenes’ and had limited or no clinical background made many of the decisions in health care. Witnessing the evolution of my mother’s career further underscored the impact of policy change on the practice of medicine. In particular, the limits legislation imposed on the care she could provide influenced my perspective and future goals. Patients whom my mother had successfully treated for more than a decade, and with whom she had long-standing, trusting relationships, were no longer able to see her, because of policy coverage changes. Some patients, frustrated by these limitations, simply stopped seeking the care they needed. As a senior in college, I wanted to understand how policy transformations came about and gain the tools I would need to help effect administrative and policy changes in the future as a physician. It was with this goal in mind that I decided to complete a master’s in public health program before applying to medical school.

As an MPH candidate, I am gaining insight into the theories and practices behind the complex interconnections of the healthcare system; I am learning about economics, operations, management, ethics, policy, finance, and technology and how these entities converge to impact delivery of care. A holistic understanding of this diverse, highly competitive, market-driven system will allow me, as a clinician, to find solutions to policy, public health, and administration issues. I believe that change can be more effective if those who actually practice medicine also decide where improvements need to be made.

For example, as the sole intern for the emergency department at County Medical Center, I worked to increase efficiency in the ED by evaluating and mapping patient flow. I tracked patients from point of entry to point of discharge and found that the discharge process took up nearly 35% of patients’ time. By analyzing the reasons for this situation, in collaboration with nurses and physicians who worked in the ED and had an intimate understanding of what took place in the clinical area, I was able to make practical recommendations to decrease throughput time. The medical center has already implemented these suggestions, resulting in decreased length of stays. This example illustrates the benefit of having clinicians who work ‘behind the scenes’ establish policies and procedures, impacting operational change and improving patient care. I will also apply what I have learned through this project as the business development intern at Another Local Medical Center this summer, where I will assist in strategic planning, financial analysis, and program reviews for various clinical departments.

Through my mother’s career and my own medical experiences, I have become aware of the need for clinician administrators and policymakers. My primary goal as a physician will be to care for patients, but with the knowledge and experience I have gained through my MPH, I also hope to effect positive public policy and administrative changes.

What’s Good About Amy’s Medical School Personal Statement:  

Paragraphs 1 and 2: Amy started her personal statement by illustrating a powerful experience she had when she realized that medical caregivers often feel impotent, and how this contrasted with her understanding of medicine as a little girl going with her mother to work. Recognition of this intense contrast also highlights Amy’s maturity.

Paragraph 3: Amy then “lists” a few experiences that were important to her.

Paragraph 4: Amy describes the commonality in some of her experiences and how her observations were substantiated by watching the evolution of her mother’s practice. She then explains how this motivated her to earn an MPH so she could create change more effectively as a physician than as a layman.

Paragraph 5: Amy then explains how her graduate degree is helping her to better understand the “issues in medicine” that she observed.

Paragraph 6: Amy then describes one exceptional accomplishment she had that highlights what she has learned and how she has applied it.

Paragraph 7: Finally, Amy effectively concludes her personal statement and summarizes the major topics addressed in her essay.

As you can see, Amy’s statement has excellent flow, is captivating and unusual, and illustrates her understanding of, and commitment to, medicine. She also exhibits, throughout her application entries and statement, the personal competencies, characteristics, and qualities that medical school admissions officers are seeking. Her application also has broad appeal; reviewers who are focused on research, cultural awareness, working with the underserved, health administration and policy, teaching, or clinical medicine would all find it of interest.

med school personal statement examples

Osteopathic Medical School Personal Statement Example and Analysis #2

Medical School Personal Statement Example Background: This is a nontraditional applicant who applied to osteopathic medical schools. With a 500 and a 504 on the MCAT , he needed to showcase how his former career and what he learned through his work made him an asset. He also needed to convey why osteopathic medicine was an ideal fit for him. The student does an excellent job illustrating his commitment to medicine and explaining why and how he made the well-informed decision to leave his former career to pursue a career in osteopathic medicine.

What’s Good About It: A nontraditional student with a former career, this applicant does a great job outlining how and why he decided to pursue a career in medicine. Clearly dedicated to service, he also does a great job making it clear he is a good fit for osteopathic medical school and understands this distinctions of osteopathic practice.. 

Working as a police officer, one comes to expect the unexpected, but sometimes, when the unexpected happens, one can’t help but be surprised. In November 20XX, I had been a police officer for two years when my partner and I happened to be nearby when a man had a cardiac emergency in Einstein Bagels. Entering the restaurant, I was caught off guard by the lifeless figure on the floor, surrounded by spilled food. Time paused as my partner and I began performing CPR, and my heart raced as I watched color return to the man’s pale face.

Luckily, paramedics arrived within minutes to transport him to a local hospital. Later, I watched as the family thanked the doctors who gave their loved one a renewed chance at life. That day, in the “unexpected,” I confirmed that I wanted to become a physician, something that had attracted me since childhood.

I have always been enthralled by the science of medicine and eager to help those in need but, due to life events, my path to achieving this dream has been long. My journey began following high school when I joined the U.S. Army. I was immature and needed structure, and I knew the military was an opportunity to pursue my medical ambitions. I trained as a combat medic and requested work in an emergency room of an army hospital. At the hospital, I started IVs, ran EKGs, collected vital signs, and assisted with codes. I loved every minute as I was directly involved in patient care and observed physicians methodically investigating their patients’ signs and symptoms until they reached a diagnosis. Even when dealing with difficult patients, the physicians I worked with maintained composure, showing patience and understanding while educating patients about their diseases. I observed physicians not only as clinicians but also as teachers. As a medic, I learned that I loved working with patients and being part of the healthcare team, and I gained an understanding of acute care and hospital operations.

Following my discharge in 20XX, I transferred to an army reserve hospital and continued as a combat medic until 20XX. Working as a medic at several hospitals and clinics in the area, I was exposed to osteopathic medicine and the whole body approach to patient care. I was influenced by the D.O.s’ hands-on treatment and their use of manipulative medicine as a form of therapy. I learned that the body cannot function properly if there is dysfunction in the musculoskeletal system.

In 20XX, I became a police officer to support myself as I finished my undergraduate degree and premed courses. While working the streets, I continued my patient care experiences by being the first to care for victims of gunshot wounds, stab wounds, car accidents, and other medical emergencies. In addition, I investigated many unknown causes of death with the medical examiner’s office. I often found signs of drug and alcohol abuse and learned the dangers and power of addiction. In 20XX, I finished my undergraduate degree in education and in 20XX, I completed my premed courses.

Wanting to learn more about primary care medicine, in 20XX I volunteered at a community health clinic that treats underserved populations. Shadowing a family physician, I learned about the physical exam as I looked into ears and listened to the hearts and lungs of patients with her guidance. I paid close attention as she expressed the need for more PCPs and the important roles they play in preventing disease and reducing ER visits by treating and educating patients early in the disease process. This was evident as numerous patients were treated for high cholesterol, elevated blood pressure, and diabetes, all conditions that can be resolved or improved by lifestyle changes. I learned that these changes are not always easy for many in underserved populations as healthier food is often more expensive and sometimes money for prescriptions is not available. This experience opened my eyes to the challenges of being a physician in an underserved area.

The idea of disease prevention stayed with me as I thought about the man who needed CPR. Could early detection and education about heart disease have prevented his “unexpected” cardiac event? My experiences in health care and law enforcement have confirmed my desire to be an osteopathic physician and to treat the patients of the local area. I want to eliminate as many medical surprises as I can.

Texas Medical School Personal Statement Example and Analysis #3

Medical School Personal Statement Example Background: This applicant, who grew up with modest means, should be an inspiration to us all. Rather than allowing limited resources to stand in his way, he took advantage of everything that was available to him. He commuted to college from home and had a part-time job so he was stretched thin, and his initial college performance suffered. However, he worked hard and his grades improved. Most medical school admissions committees seek out applicants like this because, by overcoming adversity and succeeding with limited resources, they demonstrate exceptional perseverance, maturity, and dedication. His accomplishments are, by themselves, impressive and he does an outstanding job of detailing his path, challenges, and commitment to medicine. He received multiple acceptances to top medical schools and was offered scholarships.

What’s Good About It: This student does a great job opening his personal statement with a beautifully written introduction that immediately takes the reader to Central America. He then explains his path, why he did poorly early in college, and goes on to discuss his academic interests and pursuits. He is also clearly invested in research and articulates that he is intellectually curious, motivated, hard working, compassionate and committed to a career in medicine by explaining his experiences using interesting language and details. This is an intriguing statement that makes clear the applicant is worthy of an interview invitation. Finally, the student expresses his interest in attending medical school in Texas.

They were learning the basics of carpentry and agriculture. The air was muggy and hot, but these young boys seemed unaffected, though I and my fellow college students sweated and often complained. As time passed, I started to have a greater appreciation for the challenges these boys faced. These orphans, whom I met and trained in rural Central America as a member of The Project, had little. They dreamed of using these basic skills to earn a living wage. Abandoned by their families, they knew this was their only opportunity to re-enter society as self- sufficient individuals. I stood by them in the fields and tutored them after class. And while I tried my best to instill in them a strong work ethic, it was the boys who instilled in me a desire to help those in need. They gave me a new perspective on my decision to become a doctor.

I don’t know exactly when I decided to become a physician; I have had this goal for a long time. I grew up in the inner city of A City, in Texas and attended magnet schools. My family knew little about higher education, and I learned to seek out my own opportunities and advice. I attended The University with the goal of gaining admission to medical school. When I started college, I lacked the maturity to focus on academics and performed poorly. Then I traveled to Central America. Since I was one of the few students who spoke Spanish, many of the boys felt comfortable talking with me. They saw me as a role model.

The boys worked hard so that they could learn trades that would help them to be productive members of society. It was then I realized that my grandparents, who immigrated to the US so I would have access to greater opportunities, had done the same. I felt like I was wasting what they had sacrificed for me. When I returned to University in the fall, I made academics my priority and committed myself to learn more about medicine .

Through my major in neuroscience, I strengthened my understanding of how we perceive and experience life. In systems neurobiology, I learned the physiology of the nervous system. Teaching everything from basic neural circuits to complex sensory pathways, Professor X provided me with the knowledge necessary to conduct research in Parkinson’s disease. My research focused on the ability of antioxidants to prevent the onset of Parkinson’s, and while my project was only a pilot study at the time, Professor X encouraged me to present it at the National Research Conference. During my senior year, I developed the study into a formal research project, recruiting the help of professors of statistics and biochemistry.

Working at the School of Medicine reinforced my analytical skills. I spent my summer in the department of emergency medicine, working with the department chair, Dr. Excellent. Through Dr. Excellent’s mentorship, I participated in a retrospective study analyzing patient charts to determine the efficacy of D-dimer assays in predicting blood clots. The direct clinical relevance of my research strengthened my commitment and motivated my decision to seek out more clinical research opportunities.

A growing awareness of the role of human compassion in healing has also influenced my choice to pursue a career in medicine. It is something no animal model or cell culture can ever duplicate or rival. Working in clinical research has allowed me to see the selflessness of many physicians and patients and their mutual desire to help others. As a research study assistant in the department of surgery, I educate and enroll patients in clinical trials. One such study examines the role of pre-operative substance administration in tumor progression. Patients enrolled in this study underwent six weeks of therapy before having the affected organ surgically excised. Observing how patients were willing to participate in this research to benefit others helped me understand the resiliency of the human spirit.

Working in clinical trials has enabled me to further explore my passion for science, while helping others. Through my undergraduate coursework and participation in volunteer groups I have had many opportunities to solidify my goal to become a physician. As I am working, I sometimes think about my second summer in Central America. I recall how one day, after I had turned countless rows of soil in scorching heat, one of the boys told me that I was a trabajador verdadero—a true worker. I paused as I realized the significance of this comment. While the boy may not have been able to articulate it, he knew I could identify with him. What the boy didn’t know, however, was that had my grandparents not decided to immigrate to the US, I would not have the great privilege of seizing opportunities in this country and writing this essay today. I look forward to the next step of my education and hope to return home to Texas where I look forward to serving the communities I call home.

Final Thoughts

Above all, and as stated in this article numerous times, your personal statement should be authentic and genuine. Write about your path and and journey to this point in your life using anecdotes and observations to intrigue the reader and illustrate what is and was important to you. Good luck!

Medical School Personal Statement Help & Consulting

If all this information has you staring at your screen like a deer in the headlights, you’re not alone. Writing a superb medical school personal statement can be a daunting task, and many applicants find it difficult to get started writing, or to express everything they want to say succinctly. That’s where MedEdits can help. You don’t have to have the best writing skills to compose a stand-out statement. From personal-statement editing alone to comprehensive packages for all your medical school application needs, we offer extensive support and expertise developed from working with thousands of successful medical school applicants. We can’t promise applying to medical school will be stress-free, but most clients tell us it’s a huge relief not to have to go it alone.

MedEdits offers personal statement consulting and editing. Our goal when working with students is to draw out what makes each student distinctive. How do we do this? We will explore your background and upbringing, interests and ideals as well as your accomplishments and activities. By helping you identify the most distinguishing aspects of who you are, you will then be able to compose an authentic and genuine personal statement in your own voice to capture the admissions committee’s attention so you are invited for a medical school interview. Our unique brainstorming methodology has helped hundreds of aspiring premeds gain acceptance to medical school.

Sample Medical School Personal Statement

Example Medical School Personal Statement

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The Only 3 Medical School Personal Statement Examples You Need to Read

Posted in: Applying to Medical School

Table of Contents

The personal statement is one of the most important parts of the med school application process because t his mini-essay is a critical opportunity for you to stand out from other prospective medical students by demonstrating your passion and personality, not just your grades.

Admissions committees receive hundreds or more AMCAS medical school applications , so yours should be unique and captivating. Your medical school personal statement shows admissions officers who you are beyond your high school or pre-med GPA , extracurriculars , and MCAT score . 

The best personal statements are… well, personal . This is your chance to share what life experiences have compelled you toward a career in healthcare or the medical field , and how those experiences shape the picture of your ideal future.

MedSchoolCoach has crucial advice for writing your personal statement . 

Read these examples of personal statements for prospective med students.

Writing a great medical school personal statement is a lot easier with the right support. We’ve helped numerous med school applicants craft top-notch personal statements and can do the same for you.

But first: 7 steps to writing an engaging personal statement.

Before you read these excellent examples, you need to understand the process of writing a personal statement.  

Include these in your medical school personal statement:

• Why you’re passionate about becoming a doctor
• Your qualities that will make you a great physician
• Personal stories that demonstrate those qualities
• Specific examples of the communities you want to serve as a member of the medical field

What are the most important things to remember when writing a medical school personal statement ?

• Begin the writing process early: Give yourself plenty of time for brainstorming and to revisit your first draft, revising it based on input from family members and undergrad professors. Consult the application timeline for your target enrollment season.
• Choose a central theme: An unfocused essay will leave readers confused and uninterested. Give your statement a clear thesis in the first paragraph that guides its formation.
• Start with a hook: Grab the reader’s attention immediately with your statement’s first sentence. Instead of opening with a conventional introduction, be creative! Begin with something unexpected.
• Be the you of today, not the you of the future: Forecasting your future as a physician can come across as empty promises. Don’t get caught up in your ambitions; instead, be honest about your current situation and interest in the field of medicine.
• Demonstrate your passion: It’s not enough to simply state your interest in becoming a doctor; you have to prove it through personal stories. Show how your perspectives have been shaped by formative experiences and how those will make you an effective physician.
• Show, don’t tell : Avoid cliches that admissions committees have heard hundreds of times, like “I want to help people.” Make your writing come alive with dynamic, persuasive storytelling that recounts your personal experiences.
• Tie everything together: Conclude by wrapping up your main points. Reiterate your passion for the medical profession, your defining personal qualities, and why you’ll make a good doctor.

You can read more about our recommended method in our step-by-step guide , but those are the major points.

Example 1 — From the Stretcher to the Spotlight: My Journey to Becoming an Emergency Medicine Physician

Another siren shrieks as the emergency room doors slide open and a team of EMTs pushes a blood-soaked stretcher through the entrance. It’s the fifth ambulance to arrive tonight — and only my first clinical shadowing experience in an emergency medicine department since my premed education began.

But it wasn’t my first time in an emergency room, and I knew I was meant to be here again.

In those crucial moments on the ER floor, many of my peers learned that they stumble in high-pressure environments. A few weeks of gunshot wounds, drug overdoses, broken bones, and deep lacerations in the busiest trauma bay in the region were enough to alter their career path.

They will be better practitioners somewhere predictable, like a pediatrician in a private practice where they choose their schedules, clients, and staff.

Every healthcare provider has their specialties, and mine are on full display in those crucial moments of lifesaving care. Why am I pursuing a career in Emergency Medicine? Because I’ve seen firsthand the miracles that Emergency Medicine physicians perform.

12 years ago, I was in an emergency room… but I was the one on the stretcher.

A forest-green Saturn coupe rolled into my parent’s driveway. The driver, my best friend Kevin, had just passed his driving test and was itching to take a late-night run to the other side of town. I had ridden with Kevin and his father many times before when he held his learner’s permit. But this time, we didn’t have an adult with us, and the joyride ended differently: with a 40-mph passenger-side collision, T-boned by a drunk driver.

I distinctly recall the sensation of being lifted out of the crumpled car by a paramedic and laid onto a stretcher. A quick drive later, I was in the care of Dr. Smith, the ER resident on call that night. Without missing a beat, he assessed my condition and provided the care I needed. When my mom thanked him for saving my life, he simply responded, “It’s what he needed.”

Now I’m watching other doctors and nurses provide this life-saving care as I observe as a premed student. I see the way the staff works together like a well-oiled machine, and it reminds me of my time in high-school theater.

Everyone has a role to play, however big or small, to make the show a success. All contributions are essential to a winning performance — even the technicians working behind the scenes. That’s what true teamwork is, and I see that same dynamic in the emergency department.

Some actors freeze during performances, overcome by stage fright. Other students are too anxious to even set foot in front of an audience; they remain backstage assisting with split-second costume changes.

Not me. I felt energized under the spotlight, deftly improvising to help my co-stars when they would forget their lines. Admittedly, I wasn’t the best actor or singer in the cast, but I provided something essential: assurance under pressure. Everyone knew me as dependable, always in their corner when something went awry. I had a reputation for remaining calm and thinking on my feet.

My ability to stay unruffled under pressure was first discovered on stage, but I can use it on a very different platform providing patient care. Now, when other people freeze under the intensity of serving public health on the front lines, I can step in and provide my calm, collected guidance to see them through.

As an ER doctor, I will have to provide that stability when a nurse gets flustered by a quarrelsome patient or shaken from an irreparably injured infant. When you’re an Emergency Medicine physician, you’re not following a script. It takes an aptitude of thinking on your toes to face the fast pace and unpredictable challenges of an emergency center.

During my time shadowing, I saw experienced physicians put those assured, gentle communication skills to use. A 13-year-old boy was admitted for a knife wound he’d received on the streets. He only spoke Spanish, but it was clear he mistrusted doctors and was alarmed by the situation. In mere minutes, one of the doctors calmed the patient so he could receive care he needed.

Let me be clear: I haven’t simply gravitated toward Emergency Medicine because I liked it most. It’s not the adrenaline or the pride that compel me. I owe Emergency Medicine my life, and I want to use my life to extend the lives of other people. Every person brought into the trauma bay could be another me , no matter what they look like.

People are more than their injury, health record, or circumstances. They are not just a task to complete or a challenge to conquer.

My childhood injury gave me an appreciation for the work of ER doctors and a compassion for patients, to foster well-being when people are most broken and vulnerable. I already have the dedication to the work and the heart for patients; I just need the medical knowledge and procedural skills to perform life-saving interventions. My ability to remain calm, think on my toes, be part of a team, and work decisively without making mistakes or overlooking critical issues will serve me well as an Emergency Medicine physician.

Some ER physicians I spoke with liked to think that they’re “a different breed” than other medical professionals — but I don’t see it that way. We’re just performing a different role than the rest of the cast.

Breaking It Down

Let’s look at what qualities make this a great personal statement for med school.

• Engaging opening: The writer painted a vivid scene that immediately puts the reader in their shoes and leaves them wanting more.
• Personal examples: The writer demonstrated his ability to stay calm, work as a team, and problem-solve through theater experience, which he also uses as a comparison. And, he explained his passion for Emergency Medical care from his childhood accident.
• Organized: The writer transitions fluidly between body paragraphs, connecting stories and ideas by emphasizing parallels and hopping back and forth between time.
• Ample length: Makes full use of the AACOMAS and AMCAS application personal statement’s character limit of 5,300 characters (including spaces), which is about 850-950 words.

Unsure what traits and clinical or research experience your preferred medical school values ? You can research their admissions requirements and mission statement using the MSAR .

Example 2 — Early Clinical Work For Empathetic Patient Care

The applicant who wrote this personal statement was accepted into University of South Florida Morsani College of Medicine, University of Central Florida College of Medicine, and Tufts University School of Medicine.

As I walked briskly down the hall to keep up during our daily rounds in the ICU, I heard the steady beeping of Michelle’s cardiac monitor and saw a ruby ornament twinkling on the small Christmas tree beside her. She was always alone, but someone had decorated her room for the holidays.

It warmed my heart that I wasn’t the only one who saw her as more than a patient in a coma. I continually felt guilty that I couldn’t spend more time with her; her usual companions were ventilators, IV bags, and catheters, not to mention the golf ball-sized tumors along her spine. Every day, I thought about running to Michelle’s bedside to do anything I could for her.

Thus, I was taken aback when my advisor, who was visiting me that day, asked me if I was okay. It never crossed my mind that at age 17, my peers might not be able to handle the tragedies that healthcare workers consistently face. These situations were difficult, but they invoked humanity and compassion from me. I knew I wanted to pursue medicine. And I knew I could do it.

From my senior year of high school to my senior year of college, I continued to explore my passion for patient interaction.

At the Stepp Lab, I was charged with contacting potential study participants for a study focusing on speech symptoms in individuals with Parkinson’s Disease. The study would help future patients, but I couldn’t help but think: “What are we doing for these patients in return?” I worried that the heart and soul behind the research would get lost in the mix of acoustic data and participant ID numbers.

But my fears were put to rest by Richard, the self-proclaimed “Parkinson’s Song & Dance Man,” who recorded himself singing show tunes as part of his therapy. Knowing that he was legally blind and unable to read caller ID, I was always thrilled when he recognized my voice. The spirit in his voice indicated that my interest in him and his journey with Parkinson’s was meaningful. Talking with him inspired me to dive deeper, which led to an appreciative understanding of his time as a sergeant in the U.S. military.

It was an important reminder: my interest and care are just as important as an effective prescribed treatment plan.

Following graduation, I began my work as a medical assistant for a dermatologist. My experience with a patient, Joann, validated my ability to provide excellent hands-on patient care. Other physicians prescribed her painkillers to relieve the excruciating pain from the shingles rash, which presented as a fiery trail of blisters wrapped around her torso. But these painkillers offered no relief and made her so drowsy that she fell one night on the way to the bathroom.

Joann was tired, suffering, and beaten down. The lidocaine patches we initially prescribed would be a much safer option, but I refused for her to pay $250, as she was on the brink of losing her job. When she returned to the office a week later, she held my hand and cried tears of joy because I found her affordable patches, which helped her pain without the systemic effects.

The joy that pierced through the weariness in her eyes immediately confirmed that direct patient care like this was what I was meant to do. As I passed her a tissue, I felt ecstatic that I could make such a difference, and I sought to do more.

Since graduation, I have been volunteering at Open Door, a small pantry that serves a primarily Hispanic community of lower socioeconomic families. It is gut-wrenching to explain that we cannot give them certain items when our stock is low. After all, the fresh fruits and vegetables I serve are fundamental to their culturally-inspired meals.

For the first time, I found myself serving anguish rather than a helping hand. Usually, uplifting moments strengthen one’s desire to become a physician, but in this case, it was my ability to handle the low points that reignited my passion for aiding others.

After running out of produce one day, I was confused as to why a woman thanked me. Through translation by a fellow volunteer, I learned it was because of my positivity. She taught me that the way I approach unfavorable situations affects another’s perception and that my spirited attitude breaks through language barriers.

This volunteer work served as a wake-up call to the unacceptable fact that U.S. citizens’ health suffers due to lack of access to healthy foods. If someone cannot afford healthy foods, they may not have access to healthcare. In the future, I want to partner with other food banks to offer free services like blood pressure readings. I have always wanted to help people, but I now have a particular interest in bringing help to people who cannot afford it.

While the foundation of medicine is scientific knowledge, the foundation of healthcare is the word “care” itself. I never found out what happened to Michelle and her Christmas tree, but I still wonder about her to this day, and she has strengthened my passion to serve others. A sense of excitement and comfort stems from knowing that I will be there for people on their worst days, since I have already seen the impact my support has had.

In my mind, becoming a physician is not a choice but a natural next step to continue bringing humanity and compassion to those around me.

How did this personal statement grab and sustain attention so well?

• Personalization: Everything about this statement helps you to understand the writer, from their personal experiences to their hope for how their future career will look.
• Showing, not telling: From the first sentence, the reader is hooked. This prospective medical student has plenty of great “on paper” experience (early shadowing, clinical experience, etc.), but they showed this with storytelling, not by repeating their CV.
• Empathy: An admissions committee reading this personal statement would know beyond a shadow of a doubt that this student cares deeply about their patients. They remember first names, individual details, and the emotions that each patient made them feel.
• A clear path forward: The writer doesn’t just want to work in the medical field — they have a passion for exactly how they want to impact the communities they serve. Outside of strictly medical work, they care about the way finances can limit access to healthcare and the struggle to find healthy food in food deserts around the US .

Read Next: How Hard Is It to Get Into Medical School?

Example 3 — Beyond the Diagnosis: The Importance of Individualized Care in Medicine

The applicant who wrote this personal statement was accepted into Touro College of Osteopathic Medicine and Nova Southeastern University College Of Osteopathic Medicine.

Dr. Haywood sighs and shakes her head upon opening the chart. “I was worried about her A1C. It’s up again. Hypertension, too. Alright, let’s go.”

As we enter the patient’s room, I’m expecting the news about her blood sugar and pressure to fill the room. Instead, Dr. Haywood says, “Roseline! How are you doing? How’s your girl, doing well?”

Dr. Haywood continues to ask questions, genuinely interested in Roseline’s experience as a new mother. If not for the parchment-lined examination chair and anatomy posters plastered to the wall, this exchange could be happening in a grocery store. What about her A1C? Her blood pressure? Potential Type II diabetes?

As I continue to listen, Dr. Haywood discovers that Roseline’s mother moved in with her, cooking Haitian meals I recognize as high on the glycemic index. Dr. Haywood effortlessly evolves their conversation to focus on these. Being Haitian herself, she knows some traditional dishes are healthier than others and advises Roseline to avoid those that might exacerbate her high blood sugar and blood pressure. Dr. Haywood also suggests Roseline incorporate exercise by bringing her baby on a walk through her neighborhood.

During my shadowing experience, I observed one of the core components of being a physician through several encounters like this one. By establishing a relationship with her patient where Roseline was comfortable sharing the details of new motherhood, Dr. Haywood was able to individualize her approach to lowering the patient’s A1C and hypertension. Inspired by her ability to treat the whole person , I began to adopt a similar practice as a tutor for elementary kids in underserved areas of D.C.

Shaniyah did not like Zoom, or math for that matter. When I first met her as a prospective tutee online, she preferred to keep her microphone muted and would claim she was finished with her math homework after barely attempting the first problem. Realizing that basing our sessions solely on math would be fruitless, I adapted my tutoring style to incorporate some of the things for which she had a natural affinity.

The first step was acknowledging the difficulties a virtual environment posed to effective communication, particularly the ease at which distractions might take over. After sharing this with Shaniyah, she immediately disclosed her struggles to share her work with me. With this information, I found an online platform that allowed us to visualize each other’s work.

This obstacle in communication overcome, Shaniyah felt more comfortable sharing details about herself that I utilized as her tutor. Her love of soccer gave me the idea to use the concept of goal scoring to help with addition, and soon Shaniyah’s math skills and enthusiasm began to improve. As our relationship grew, so did her successes, and I suspect the feelings I experienced as her tutor are the same as a physician’s when their patient responds well to prescribed treatment.

I believe this skill, caring for someone as a whole person , that I have learned and practiced through shadowing and tutoring is the central tenet of medicine that allows a doctor to successfully treat their patients.

Inspired by talking with patients who had received life-altering organ transplants during my shadowing experience, I created a club called D.C. Donors for Georgetown University students to encourage their peers to register as organ donors or donate blood. This experience taught me that to truly serve a person, you must involve your whole person, too.

In starting this club to help those in need of transplants, I had to dedicate my time and effort beyond just my physical interactions with these patients. For instance, this involved reaching out to D.C.’s organ procurement organization to inquire about a potential partnership with my club, to which they agreed. In addition, I organized tabling events on campus, which required significant planning and communication with both club members and my university.

Though exciting, starting a club was also a difficult process, especially given the limitations the pandemic imposed on in-person meetings and events. To adapt, I had to plan more engaging meetings, designing virtual activities to make members more comfortable contributing their ideas. In addition, planning a blood drive required extensive communication with my university to ensure the safety of the staff and participants during the pandemic.

Ultimately, I believe these behind-the-scenes actions were instrumental in addressing the need for organ and blood donors in the D.C. area.

From these experiences, I have grown to believe that good medicine not only necessitates the physician cares for her patient as a whole, but also that she fully commits her whole person to the care of the patient. Tutoring and starting D.C. Donors not only allowed me to develop these skills but also to experience such fulfilling emotions: the pride I had in Shaniyah when her math improved, the gratefulness I felt when she confided in me, the steadfast commitment I expressed to transplant patients, and the joy I had in collaborating with other passionate club members.

I envision a career as a physician to demand these skills of me and more, and I have confirmed my desire to become one after feeling so enriched by practicing them.

Here’s what makes this personal statement such a good example of what works:

• Desirable qualities: The student clearly demonstrates qualities any school would want in an applicant: teachability, adaptability, leadership, organization, and empathy, to name a few. This again uses the “show, don’t tell” method, allowing the readers to understand the student without hand-holding.
• Personalized storytelling: Many in the healthcare profession will connect with experiences like the ones expressed here, such as addressing patient concerns relationally or the lack of blood donors during the recent pandemic. The writer automatically makes a personal link between themselves and the admissions committees reading this statement.
• Extensive (but not too long): Without feeling too wordy, this personal statement uses nearly all of the 5,300 characters allowed on the AMCAS application. There’s no fluff left in the final draft, only what matters.

Avoid These Common Mistakes

You can learn a lot from those personal statements. They avoid the most common mistakes that med school applicants make when writing the medical school personal statement.

Here are some things you should avoid in your personal statement if you want to be a doctor:

• Name-dropping: Admissions counselors won’t be impressed when you brag about your highly regarded family members, associates, or mentors. You need to stand on your own feet — not someone else’s.
• Dishonesty: Lies and exaggerations can torpedo your application. And they’re bad habits for anyone entering the medical field. Don’t do it.
• Unedited AI content: Artificial intelligence can help you edit and improve your writing, but don’t let it do the work for you. Your statement needs to be authentic, which means in your voice! A chatbot can’t feel or adequately convey your own empathy, compassion, trauma, drive, or personality.
• Grammatical errors and typos: Have someone reliable proofread your essay and scour it for typos, misspellings, and punctuation errors. Even free grammar-checking apps can catch mistakes!
• Telling without showing: I’ll reiterate how important it is to prove your self-descriptive statements with real-life examples. Telling without showing won’t persuade readers.
• Too many examples: Have 3-4 solid personal stories at most; only include a few that are crucial for providing your points. The more experiences you share, the less impact they’ll make.
• Fluff and filler: Cut all fluff, filler words, and irrelevant points. There are many other places you can include information in your application, such as secondary essays on your clinical experience, volunteer work, and research projects . 

You can find more valuable do’s and don’ts in our in-depth guide to writing your best personal statement .

Need extra help? We’ve got you covered.

Schedule a meeting with medschoolcoach for expert support on writing and editing your personal statement. we’re here to help you impress medical school admissions committees .

Renee Marinelli, MD

Dr. Marinelli has practiced family medicine, served on the University of California Admissions Committee, and has helped hundreds of students get into medical school. She spearheads a team of physician advisors who guide MedSchoolCoach students.

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Medical School Personal Statement Storytelling Guide [With Examples]

Typical medical school personal statements list qualities and accomplishments in paragraph form and can be boring to read for admissions committee members. But the best personal statements demonstrate qualities through engaging stories. Those stories reveal insights into your personality, as well as interests outside healthcare and medicine (especially those that align with the medical schools you’re applying to ).

Medical school admissions committees want to learn who you uniquely are and why you want to become a medical professional. They also want to know what you are going to contribute to their school and the larger medical field.

Our in-depth guide will help you explore unique personal topics and stories to capture admission committee members’ attention and help you stand out in a sea of ordinary med school personal statements.

Table of contents

1. brainstorm topics, 2. choose stories that show your character, show, don’t tell, stay on topic, common medical school personal statement mistakes, get an expert’s opinion.

The first step in the personal statement writing process is to decide what stories and facts are most important to reveal and how to weave in your motivation for applying to a school of medicine.

When you’re ready to brainstorm, don’t just sit down to stare at a list of your premed activities like research experiences, volunteering, or shadowing. Instead, compile the fundamental personal experiences and people that helped shape you. These stories will likely translate beyond your personal statement into interviews , so be picky to choose only the most transformative.

When brainstorming your personal statement for medical school, consider these topics:

Significant or formative life experiences: something that changed the course of your life, your outlook on the world, or made you think differently about your future

• Learning to do something that leads you to excel/teach others/make a contribution (e.g., sports, science, foreign language, special skills)
• Being given a second chance
• Connecting with someone who made an impact on you
• Being out of your comfort zone (experiences with people of different backgrounds, travel, moving, doing something for the first time)

Challenging life experiences: something that forced a lesson upon you

• A mistake you made
• An event that was out of your control that nonetheless caused you suffering or loss
• Overcoming an obstacle

People that shaped your life:

• Mentor, family member, friend
• Author, actor, speaker, personal hero

Think about what each element on your list taught you or how it changed your thinking. Answer for yourself why the event or person is important. Then brainstorm how one or two medically related activities can be tied in.

With this strategy, your personal statement will develop around a narrative that is unique to you. It will also communicate to admissions officers who you are and why you want to provide medical care.

To further your thought processes, ask yourself these questions:

• What is distinct or unique about you/your life story?
• What are some specific details about your personality, values, or experiences you can share to help them get a better understanding of who you are?
• In what ways have your experiences contributed to your growth?
• Have you overcome any obstacles or difficult circumstances in your life?
• What valuable personal characteristics (integrity, compassion, diligence, etc.) do you have?
• What soft skills (leadership, teamwork, communication skills, etc.) do you have?

Next, connect those answers to medicine-specific questions:

• How and when did you become interested in medicine?
• What have you learned so far about medicine?
• Why do you want to become a doctor?
• How do you know you want to be a doctor?
• How have your experiences and your understanding of yourself confirmed your desire to do medicine?
• In what ways have you shown that you have the characteristics necessary to succeed in the field of medicine?
• How will your skills translate into being a good doctor?
• Are there any gaps or discrepancies in your academic record that need explaining? This can be an obstacle or difficult circumstance.

Though you don’t want to include the answers to all these questions in your personal statement, knowing the answers to these questions is a good starting point.

You should highlight a few unique experiences, skills, or personal characteristics and make those the focal point of your essay.

Ordinary personal statements focus on the experiences that applicants think will make them seem impressive. The best personal statements focus on the qualities that make applicants truly special.

Instead of choosing their standout qualities — character, personality traits, attitudes — many applicants simply choose experiences they think will help them stand out to admissions committees. Then, they try to force those qualities into the experiences they’ve already chosen.

Why is this an issue? Imagine you have participated in the following extracurricular activities:

• Biochemistry research for 2 years
• Clinical experience shadowing for 3 years
• Math tutor for underserved youth for 2 years
• Trombonist in the high school band and trombone instructor for 3 years
• International medical mission trip volunteer for 3 summers
• Premed organization member for 3 years (vice president for 1 year)

At face value, which of these experiences do you think would make you seem the most impressive to an admissions committee? Given these choices, most students would choose to write about clinical shadowing (2) or medical mission trips (5).

Most students who choose one of those two topics will take a very similar approach, such as starting off the essay describing some interaction with a very ill patient or one with whom they experienced a language barrier.

Typical Applicant Personal Statement Example:

“Mary was well known at our clinic by all of our doctors, nurses, and medical staff. Based on her sharp intellect and cheerful pattern of making our staff feel like we were her best friends, it would be difficult to tell why she frequently visited the hospital. Besides her use of a walker, her Parkinson’s disease diagnosis had not slowed her down much. Throughout my interactions with Mary, I wondered how she maintained such a positive attitude despite her ailments. She seemed to give our staff more joy with her beaming smile than receiving care. I wanted to give her the best care possible, whether through asking our great nurses to check in on her or offering an extra blanket or favorite snack to ensure comfort throughout her stay. However, I was simultaneously frustrated that my ability to help Mary ended there. This lingering lack of fulfillment has served as a great motivator to find ways to do more for patients like her.”

What’s wrong with this example?

Although the above example provides some insights about the applicant’s motivations (“…find ways to do more for patients…”), it is written about a common topic (a realization that came during clinical shadowing) with a typical delivery —  written broadly about interactions with a particular patient.

The best personal statement writers, on the other hand, first think of the personal qualities they want to demonstrate in their essay before choosing a situation or event to write about. Next, they think of an experience that best highlights these qualities, regardless of whether or not it seems most “impressive” at face value. Finally, the best personal statements zero in on a particular event or situation to capture the reader’s attention with a detailed personal story.

By taking this approach, the best personal statement writers are better able to demonstrate their qualities because their story was chosen expressly for that purpose. After all, schools are attracted to particular candidates because of their qualities and not a specific experience they’ve had.

Let’s suppose this same applicant wanted to highlight her community involvement and commitment to serving underprivileged groups. Returning to the list of extracurriculars above, she could choose to write about working as a math tutor (3) or being a trombonist in the school band and trombone instructor (4). By choosing the latter and zooming in on a particular event, this same student could write the following personal statement introduction:

Better Personal Statement Example:

“My palms had never been as sweaty as when I walked on stage with my trombone in front of a 500-plus member audience on June 9th, 2015. Sure, I was pretty good. But I would like to think that being invited to play Curtis Fuller’s “Along Came Betty” at the Omaha Black Music Hall of Fame had as much to do with the music skills I had honed over the past decade as it did with training the 8-member band of 10 to 13 year-olds from the inner city to join me on that same stage. I was nervous because this performance was for them; I needed to be at my best.”

Why is this example better than the one before it?

This introduction would likely stand out because it is about an uncommon topic (a musical performance) and seamlessly demonstrates the writer’s community involvement, especially with underserved youth. As a bonus, it captures the reader’s attention in 382 fewer characters.

Typical personal statements could have been written by any applicant. Good personal statements are those that can only be written by a specific applicant. The example of a typical introduction could have been written by any number of medical students who volunteered in a hospital. There simply aren’t enough unique insights and details about the applicant. On the other hand, the second introduction could have only been written by that individual.

So, how do you avoid a dull introductory paragraph? Use the approach above — first, list your unique qualities, then identify situations where you’ve expressed those qualities, and finally, zoom in to tell a detailed story.

Want to improve your chances of acceptance? Get world-class coaching from former admissions committee members for a more compelling personal statement and polished application. Students who work with us double their chances of getting accepted!

You’ve likely heard the adage “Show, don’t tell” enough already. Rarely do we receive practical advice on exactly how to demonstrate our qualities, rather than list them. When you can do this, you provide a more authentic glimpse of who you really are.

If you read the following sentences from two different applicants, which one would you think was more giving?

• Applicant #1: I am a very giving person.
• Applicant #2: I volunteer 4 hours every week to work at the homeless shelter.

You’d probably choose applicant #2, even though they never used the word “giving” in their sentence. As a reader, we extrapolate how giving that applicant is.

Going back to the intro paragraphs above, we can see that the typical one “tells” about the applicant’s qualities, whereas the better paragraph “shows” the applicant’s qualities.

More Medical School Personal Statement Examples :

Typical introductions:

• “I wanted to give the best patient care possible…” (giving)
• “This lingering lack of fulfillment has served as a great motivator to find ways to do more” (motivated)

Better introductions:

• “…the music skills I honed over the past decade…” (dedicated)
• “…training the 8-member band of 10-13 year-olds from the inner city to join me on that same stage.” (giving, empowering)
• “I was nervous because this performance was for them; I needed to be at my best.” (selfless, motivated)

Strive to let your accomplishments, approaches, and insights speak for themselves. Describe your work in an engaging way and let the reader do the complimenting for you.

Some applicants make the mistake of putting the focus on supporting characters, like a parent or patient, making them more compelling than themselves or sharing the limelight. But the best personal statements maintain the focus on the applicant.

Like any great story, your personal statement should highlight a compelling character. But that character, the star of your story, should always be YOU. There is nothing wrong with including another character in your personal statement’s story. But other characters should only be used to demonstrate your qualities, whether through an interaction you had or an insight you gained after.

Returning to our examples above:

In the typical paragraph, Mary and the applicant are co-leads in the story. We don’t even read about the applicant or her insights until the fourth sentence. Mary seems just as impressive as the applicant.

The better paragraph is all about the applicant — her concerns, dedication, and motivations. Even though she mentions the inner-city youth, they serve only to demonstrate the applicant’s qualities.

Your opportunity to impress med school admissions committees with your personal statement is limited to 5,300 characters. Strive to keep the focus nearly entirely on you.

Know ahead of time that your first draft is just that — a first draft. Once you get something on the page, you can start rewriting and revising it into the perfect statement.

Explaining the answer to “Why I want to be a doctor” can be overwhelming. Many applicants end up making the mistake of answering a different question: “What have I done that qualifies me for medical school?” The result is a tedious list of GPAs and MCAT scores that make personal statements read like a resume.

A better approach is not to focus on the question that your essay will answer, but on the personal aspects of your experiences on earth that shaped who you are — a person whose goals and values align with entering the medical profession.

More common mistakes to avoid:

• Not being concise
• Using clichés
• Breaking character limits
• Not using transitions between paragraphs and topics
• Not getting a second opinion or consulting an expert

There are some red flags to keep in mind as well. Admissions experts will not be impressed with:

• Arrogance or narcissism
• Self-deprecation or lack of confidence
• Unexplained gaps in education
• Generalizations
• Poor grammar
• Lack of passion

Read Next: A Guide To Medical Schools That Don’t Require The MCAT

What is the AMCAS personal statement prompt?

The AMCAS personal statement prompt is: Use the space provided to explain why you want to go to medical school.

How many characters are allowed in the medical school personal statement?

You can use up to 5,300 characters in the medical school personal statement sections of the AMCAS and AACOMAS applications . Spaces count as characters. You’ll have roughly 500 words to write.

How long should a personal statement be for medical school?

A personal statement for medical school should be approximately one page. It should be long enough to take a deep look at a transformative experience or concept.

What personal statement topics should I avoid?

There are no specific topics that you should completely avoid in your personal statement outside of openly offensive topics. You may receive advice to steer clear of topics like mental health, having a parent who’s a doctor, or volunteer work. But it’s not these topics themselves that are a problem; how you use these stories and experiences to show your personality and character is what matters.

Your personal statement is one of the few times in the medical school application process where your personality, experiences, and uniqueness can shine through. It’s too important to leave it to guesswork, particularly if you’re reapplying !

Work with experienced Writing Advisors and Physician Advisors to give your personal statement the X factor sure to be noticed by admissions committees. Many of our advisors are former AdComs !

Related posts:

• Why I Picked UC Denver
• Finding the Perfect Research Project
• How to Succeed on Medical School Interview Day
• How to Answer “What is the Biggest Healthcare Problem” During an Interview

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How to Write a Perfect Medical School Personal Statement: A Complete Guide

Writing a personal statement for medical school can be a daunting task, but it’s an important part of your application that can set you apart from other candidates. A medical school personal statement requires you to reflect on your experiences and communicate your passion for medicine in a compelling way. But there is a word limit, and being concise can be challenging. However, with careful planning and preparation, it is possible to write a strong and effective personal statement. Here are some tips to help you.

7 Important Tips for Writing a Perfect Personal Statement for Medical School

A strong personal statement can significantly affect your medical school application. Here are seven tips that you need to remember when writing your personal statement. 

Start with an engaging opening:

 Your opening sentence should grab the reader’s attention and make them want to read more. Consider starting with a personal story, a thought-provoking question, or a bold statement.

Showcase your motivation: 

Medical school admissions committees want to know why you want to become a doctor. Share your personal motivation for pursuing medicine, whether it’s a desire to help others, a personal experience that inspired you, or a specific aspect of the field that interests you.

Highlight your experiences:

 Use specific examples to illustrate your interest in medicine and your suitability for the profession. This could include volunteer work, research experience, clinical exposure , or any other activities related to medicine .

Discuss your strengths:

Highlight the strengths and qualities that make you a strong candidate for medical school. This could include your leadership skills, teamwork abilities, or resilience in the face of challenges.

Be authentic: 

Write in your own voice and be honest about your experiences and motivations. Avoid clichés and generic statements.

Keep it concise: 

Your personal statement should be no longer than two pages, so be sure to prioritize the most important information and avoid unnecessary details.

Edit and proofread:

 Take the time to revise and proofread your personal statement. Ask others for feedback and make sure your writing is clear, concise, and error-free.

Remember, your personal statement is your chance to showcase your unique qualities and experiences. Use this opportunity to demonstrate your passion for medicine and your suitability for the profession.

How long should a medical school personal statement be?

The length of a medical school personal statement can vary, but most medical schools have specific guidelines on the length. Typically, a personal statement should be no longer than 1-2 pages or about 500-800 words. However, some schools may have different requirements, so it’s important to check each school’s guidelines before writing your personal statement.

While it may be tempting to include as much information as possible, it’s important to remember that the admissions committee will be reading many personal statements , so it’s important to keep yours concise and to the point. Focus on the most important information, such as your motivation for pursuing medicine, your relevant experiences, and your unique qualities and strengths. Be sure to follow the guidelines provided by the schools you are applying to and proofread carefully to ensure that your personal statement is clear, concise, and error-free.

Medical School Personal Statement Format

There is no set format for a personal statement for medical school, but there are some general guidelines you should follow. Here is a basic outline that you can use:

• Introduction: Begin with an attention-grabbing opening that introduces yourself and your interest in medicine.
• Body Paragraphs: Write two or three paragraphs to elaborate on your qualities and experiences. This section gives you the opportunity to convince the admissions committee that you are the perfect fit for this profession.
• Conclusion: Summarize your main points and reiterate your motivation for pursuing medicine.

Remember, this is just a general outline, and you should customize your personal statement to fit your own experiences and strengths. Be sure to focus on your unique qualities and experiences and show the admissions committee why you are a great fit for their program. Also, keep in mind any specific requirements or prompts that the medical school may have provided.

Introduction Paragraph

The introduction of your personal statement is the first impression the admissions committee will have of you, so it’s important to make it great. Here are some tips for writing a strong personal statement introduction:

Start with a hook:

 Begin with a sentence or two that will grab the reader’s attention and make them want to keep reading. This could be a personal story, a surprising fact, or a bold statement.

Introduce yourself: 

In the first few sentences, introduce yourself and briefly mention your background or experiences that have led you to pursue medicine.

Share your motivation:

 The admissions committee wants to know why you want to become a doctor, so be sure to share your personal motivation for pursuing medicine. This could be a personal experience, a desire to help others, or a specific aspect of the field that interests you.

Show your enthusiasm:

 Demonstrate your enthusiasm for medicine and your eagerness to learn and contribute to the field. Avoid sounding cliché or insincere.

Be concise: 

Keep your introduction brief and to the point. Remember, you only have a limited amount of space for your personal statement, so use it wisely.

Remember, your introduction sets the tone for the rest of your personal statement, so make sure it’s engaging, authentic and reflective of your passion for medicine.

Body Paragraphs

The body paragraphs of your medical school personal statement are where you will showcase your experiences, qualities, and skills that make you a strong candidate for medical school. Here are some tips for writing great body paragraphs:

Use specific examples: 

Instead of making general statements, use specific examples to illustrate your experiences and qualities. This will make your personal statement more engaging and memorable.

Be authentic:

 Write in your own voice and be honest about your experiences and motivations. Avoid using clichés or sounding insincere.

Show, don’t tell:

 Rather than simply stating your qualities, show how you’ve demonstrated them in your experiences. This will make your personal statement more compelling.

Stay focused:

 Keep your personal statement focused on your experiences and qualities that are relevant to medicine. Avoid including irrelevant or unnecessary information.

Use transitions:

 Use transition words or phrases to smoothly connect your ideas and make your personal statement flow well.

Convey your growth:

 Use your experiences to show how you’ve grown and learned and how they’ve prepared you for medical school.

Be concise:

 Keep your body paragraphs concise and to the point. Avoid going off on tangents or including too much information.

Remember, your body paragraphs are where you will show the admissions committee why you are a strong candidate for medical school. Use specific examples to showcase your experiences, qualities, and skills, and make sure they are relevant to medicine.

Conclusion Paragraph

The conclusion paragraph of your medical school personal statement is your last opportunity to leave a lasting impression on the admissions committee. Here are some tips for writing a great conclusion paragraph:

Summarize your main points:

 Briefly summarize the key points you’ve made in your personal statement. This will remind the reader of your main message and help tie your personal statement together.

Reiterate your motivation:

 Remind the reader why you are passionate about medicine and why you want to become a doctor.

Connect to the future:

 Make a connection between your experiences and your future goals as a physician. Show the admissions committee that you have a clear understanding of what it means to be a doctor and how you plan to contribute to the field.

End with a strong statement:

 End your personal statement with a powerful statement that leaves a lasting impression on the reader. This could be a personal anecdote, a memorable quote, or a final reflection on your experiences.

Avoid Repetition:

Keep your conclusion paragraph concise and to the point. Avoid repeating information from earlier in your personal statement or introducing new information.

Remember, your conclusion paragraph is your last chance to make a strong impression on the admissions committee. Make sure it leaves a lasting impression by summarizing your main points, reiterating your motivation, and connecting to your future goals as a physician. End with a strong statement that shows your passion and commitment to the field of medicine.

6 Cliché Phrases that You Should Avoid in Your Medical School Personal Statement

When writing your medical school personal statement, it’s important to avoid using clichés. These are overused phrases or ideas that have lost their impact and can make your personal statement appear generic and unoriginal. Here are some medical school personal statement clichés to avoid:

“Ever since I was a child, I’ve wanted to be a doctor.” 

While it’s important to show your motivation for medicine, this cliché is overused and doesn’t provide any unique insight into your experiences or qualities.

“I want to help people.”

 While helping others is a noble goal, this statement is too broad and doesn’t provide any specific examples of how you’ve helped others in the past.

“I’ve always been interested in science.”

 While it’s important to show your interest in science and medicine, this statement is too general and doesn’t provide any specific examples of how you’ve pursued your interests.

“I’ve faced many challenges, but I’ve overcome them all.”

 While it’s important to show your resilience and ability to overcome obstacles, this cliché is overused and doesn’t provide any unique insight into your experiences or qualities.

“I’ve always been a hard worker.”

 While it’s important to show your work ethic, this statement is too general and doesn’t provide any specific examples of how you’ve worked hard in the past.

“I have a passion for helping underserved communities.”

 While it’s important to show your commitment to serving others, this cliché is overused and doesn’t provide any specific examples of how you’ve worked to serve underserved communities in the past.

To make your personal statement stand out, try to provide specific examples and insights into your experiences and qualities rather than relying on overused clichés. Show the admissions committee what makes you unique and why you would make a great candidate for medical school.

Should Applicants Address Bad Grades in their Medical School Personal Statement?

It is generally not recommended to mention bad grades in your medical school personal statement, as it may draw unnecessary attention to a negative aspect of your application. The personal statement is your opportunity to showcase your strengths, experiences, and qualifications that make you a strong candidate for medical school.

Instead of focusing on any negative aspects of your medical school application, you should focus on highlighting your positive attributes and accomplishments. You can use your personal statement to describe your experiences in healthcare or other related fields, explain why you are passionate about medicine, and demonstrate your dedication to the field.

If you have any extenuating circumstances that led to your lower grades, such as a personal or medical issue, you may want to address them in your application elsewhere, such as in an optional essay or during an interview. However, if your grades are simply the result of not performing well in certain courses, it is best to focus on your strengths and achievements in your personal statement.

Remember that the personal statement is just one component of your medical school application , and the admissions committee will consider your entire application when making their decision. If you have concerns about your grades or other aspects of your application, you can reach out to Jack Westin experts for guidance.

► To learn more about different aspects of a medical school application. You can watch This VIDEO .

In this post, we elaborated on different aspects of writing a medical school personal statement. Remember that there is no one “perfect” medical school personal statement, as each applicant’s personal statement will be unique to their experiences and qualifications. However, a strong medical school personal statement should provide insight into who you are as a person and as a potential doctor. It should demonstrate your passion for medicine, your unique qualities and experiences, and your potential to make a meaningful contribution to the field of healthcare.

If you need help with your personal statement or any other aspect of your medical school application, CONTACT US ! Jack Westin experts are by your side on your path to medical school . 

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Medical School Sample Personal Statements

These are real personal statements from successful medical school applicants (some are from students who have used our services or from  our advisors ). These sample personal statements are for reference purposes only and should absolutely not be used to copy or plagiarize in any capacity. Plagiarism detection software is used when evaluating personal statements. Plagiarism is grounds for disqualification of an applicant.

Disclaimer: While these essays ultimately proved effective and led to medical school acceptances, there are multiple components that contribute to being an effective medical school applicant. These essays are not perfect, and the strengths and weaknesses have been listed where relevant.

Get 10 More Medical School Personal Statements

We'll send a PDF straight to your inbox containing 10 more stellar personal statements with expert breakdowns.

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Sample personal statements.

“I love Scriabin!” exclaimed Logan, a 19-year-old patient at the hospital, as we found a common interest in the obscure Russian composer. I knew Logan’s story because it was so similar to my own: a classically-trained pianist, he was ready to head off to college in a month, just as I had the year before. Yet it was Logan who was heading into surgery to remove a recently-discovered brain tumor. Hoping to assuage his fears of the daunting operation, I lent him my iPod full of Scriabin’s music. Though the surgery began normally, a few hours later, Logan’s blood pressure started dropping, and he became unresponsive to monitoring provided by the surgical neurophysiologist. As the nurses scrambled to stabilize him, I finally heard the neurosurgeon ask, “Did we lose him?” These four terse words immediately unnerved me. Logan was in the most critical and uncertain situation I could imagine, while the iPod I had lent him, a reminder of the conversation we had just a few hours earlier, was eerily visible on the other side of the room. While Logan, fortunately, went on to make a full recovery after a successful surgery, I was not ready to hear those four frightening words.

Perhaps I was so unnerved by those words because of my experiences with my mother’s sicknesses. My father and I try to be mentally prepared to lose her any day. With a Borderline Personality Disorder diagnosis, my mother has struggled with suicidal tendencies for most of my life. Her other illnesses, including several autoimmune disorders and severe gastrointestinal problems, certainly hinder her from experiencing the joys of life. But what is most difficult for me and my father is her anger and violence when she is in pain. My father would remind me that I had to consider the sources of her feelings, however irrational, in order to communicate with her. Though my relationship with my mother has proved challenging, I am thankful for these experiences.

In medicine, I will be able to use these experiences to understand psychological barriers to wellness and to better empathize with the patients I see in the clinic. Unique life experiences like these helped when I met Enrique, a patient presenting with an unusually painful fungal infection on one of his toenails. Though he was aware that his condition posed no lasting threat to his health, the extreme pain of the infection made him apprehensive of treatment, a soak in Povidone-iodine solution. “How can I help this man?” I asked myself, “He is about to refuse a simple treatment for a painful ailment.” Hoping to calm him, I struck up a conversation in Spanish, which I learned while living for some months in Cuernavaca, Mexico. This was not enough. As he became increasingly uneasy about the impending treatment, I remembered a line from Federico García Lorca’s “Romance de la Pena Negra”: “…wash your body with the water of the lark / and leave your heart in peace.” As Enrique calmly placed his foot into the “lark’s water,” I was relieved to see that this was the encouragement he needed. I believe that my travels have helped me appreciate the cultural backgrounds of many patients and have prepared me to be an empathetic clinician.

While I have been prepared to address patients psychologically and culturally, my training in the lab has prepared me to address patients biologically as well. Having worked extensively in two different labs studying vaccine development and microbial pathogenesis, I have developed a desire to use bench research to improve clinical care. One particularly striking manifestation of this concept came at the beginning of my day at an internist’s clinic. Walking into the office, I heard a most unsettling sound—a distinctive, screeching, painful yelp audible throughout the clinic. I instantly knew what case I would be seeing next: Whooping cough. When I saw Brody, a toddler, I was arrested by a unique commiseration, one of both pity and curiosity. I knew exactly what was happening to Brody. I had spent the last two years performing research on the bacteria that caused the disease,  Bordetella pertussis . Describing elements of the microbe’s pathogenesis and explaining how our research could improve vaccine efficacy was comforting to the family, and their response was encouraging to me as I continue my work. My research experiences have engendered a passion to be at the cutting edge of medicine, seeking always to improve patient care, so that in the future, I can come to a family like Brody’s with a better prognosis.

Though I may not have been prepared to hear those frightening words during Logan’s surgery, what I can say with confidence is that I am ready to begin the journey of a physician—the journey of a lifelong learner and a committed healer. I am ready to be challenged by difficult situations in the clinic, like Logan’s, because it is through those circumstances that I will learn and grow. I want to become a physician so that I can use my liberal arts education with my personal and professional experiences to meet medicine’s unique requirement of understanding patients psychologically, culturally, and biologically. I am ready to provide the most excellent patient care, empathetically and holistically appreciating my patients’ stories in order to serve them best.

The author masterfully weaves together multiple elements of his unique experiences in medicine to tell a compelling story. This an excellent example of “show, don’t tell”, whereby the author tells stories and takes the reader on a journey rather than simply listing what he did in the past.

For example, rather than explicitly stating that he did research on Bordetella pertussis, the author tells a story of a patient with Whooping cough and interweaves his research experience there, tying together a message of the future doctor’s interest in translational (from bench to bedside) research. Similarly, rather than explicitly stating he did experience A, and learned important lesson B and C, these themes are implied more indirectly. As a result, the essay reads smoothly as a story, and grips the reader.

The author’s voice comes through, transitions are smooth, the introduction engages the reader, and the story arc neatly comes full circle. The character limit was pushed to the limit (5,299) and the author made every word count. Fantastic essay.

The main reason why I want to go into medicine is because of a promise I made to my sister when I was eight years old. My sister, who was only a few months old, was aware I had been taking care of her while our parents were working late. Caring for her gave me a feeling of responsibility I had never experienced before. When my sister woke up with a fever, I felt helpless. Her doctor was able to take care of the most important person in my life by systematically ruling out possible causes for the fever while still helping my sister feel safe, allowing me to see the beauty of medicine. I made a promise to my sister to become a medical doctor, so I can take care of her and other people who cannot take care of themselves. Later, my mother explained to me that medicine had made my life possible because I had been conceived through in vitro fertilization. This reinforced my motivation to become a physician and encourages me to this day to come full circle and give back to the field that made my life possible by helping others in need.

I continued to pursue my dream of practicing medicine by volunteering in the Intensive Care Unit at the UC San Diego Thornton Medical Center, where I gained first-hand experience interacting with patients. While collecting laboratory samples from nurses, I talked to a patient who only spoke Spanish. As the interpreter had not arrived yet, I was the only Spanish speaker in the unit, and my Spanish was basic at best. I asked the patient about her day and family, which really lifted her spirits. This interaction taught me the importance of personal connections with patients.

Shadowing allowed me to learn the characteristics of a good physician. Before surgeries, I obtained the patient’s consent to let me observe the procedure while the surgeon went over the patient’s last minute concerns. One patient needed an Aortic Valve Replacement, and when I was getting his consent he told me he was a famous Italian singer. The surgeon asked him to sing his hit song, and I was amazed. The patient’s face lit up and all his worries faded before the surgery. Even though the patient was going to be heavily sedated, the surgeon still cared about the patient’s stress about the procedure and that really drew me to the profession and showed me that there is more to being a good doctor than just the technicalities or knowledge from textbooks.

Volunteering at a veterans’ hospital exposed me to a side of medicine I have only read about in the news. People who are underserved and undereducated who refuse medical care. I would call patients who could not go to any other hospital and try to convince them to have their eyes checked for diabetes symptoms in the Teleretinal Imaging department. One veteran answered my call with a groan asking why he needs to go to the hospital when he knows he does not have diabetes. I realized I had to explain to him that symptoms can develop well before the actual disease. This inspired me to help patients in underprivileged communities because some are not educated enough to know when something is wrong with their bodies.

I know if I am given the chance to practice medicine and serve as a leader in the African American community, I can deliver the same inspiration and become a role model for those who are disadvantaged. At UC San Diego I joined the Black Student Union where I was able to reach out to those who were unsure about pursuing a higher education. Speaking to high school students about my college experiences has improved my communication skills and ability to relate to diverse populations. I spoke about how college can open many more opportunities for these students and that there are countless resources and scholarships that can help them. I will use simple and direct communication to help patients understand their disease. Through this experience, I knew I wanted to practice medicine that is personal through interaction with minority communities. After these events, it is clear to me that I cannot give up on my dreams of becoming a doctor because when I rise I will also lift those around me with the same struggle.

In elementary school, I realized there was a lack of famous African-American physicians, so I asked my parents if they knew of anyone. My father told me about my uncle, Roy Harris, who grew up in the inner city, surrounded by drugs and gangs. In order to avoid these hardships, he joined the high school track team and continued running through college while pursuing his medical degree. I began running to remind myself of his inspiring story and, like him, encourage a change in the world so one day students will have more African-American doctors to emulate. I am currently one of the top athletes in the nation, an Academic All-American, and I hope to compete at NCAA Division II nationals next year. Running has given me the discipline to maintain a balanced life, provided me the focus to succeed in medical school, and given me the drive to work toward fulfilling my dreams. Most importantly, I made a promise to my sister, creating an unshakeable foundation of endless motivation that will encourage me even through the most distressing moments of my journey to become a physician. I will never give up nor surrender because I always keep my promises.

The author uses an anecdote to start and finish the essay, which is a common and effective way to create a story arc. He calls back to multiple experiences throughout his life, from childhood to adolescence to young adulthood to bolster his resolve for pursuing medicine. His interesting background and stories, such as the promise he made to his sister, and his inspiration for picking up track, make for unique elements in this personal statement.

While the author does reflect back to multiple experiences, this comes across more as “telling” than “showing”. Compare this to the essay above to see the difference. The author has a common and repeating paragraph structure of 1) explain what the extracurricular or experience is, 2) recount a story related to said experience, and 3) draw lessons learned. While this structure gets the point across, it does not come across as engaging or compelling to the reader.

The author’s desire to give back to the African American community as well as his high aspirations are admirable.

At the beginning of the first Alternative Spring Break (ASB) meeting that I was leading in front of a group of nervous volunteers, I used an icebreaker, Two Truths and a Lie. Being a common face at my campus’s student activities, I have played this game perhaps one too many times. Unlike everyone else who had to take time to think about their interesting truths, I would say the same thing every time. “I want to be a pediatrician, I have alpacas, and I have llamas.”

I do not have llamas.

Growing up on a farm has given me great pride throughout the years and has driven my passion for service to my community, leading me to the goal of a career as a pediatrician. The farm is where I was first introduced to medicine. I would assist my father give shots to our animals, help our alpacas give birth to their crías, and talk with our family veterinarian about his treatment methods. The farm spawned in me a love for science which has shaped my career path, and my knowledge acquired through the farm has been a pleasure to share with people. My mother and I would visit the special education classrooms of different schools to show the kids presentations of the farm. We would lead demonstrations of us cleaning, spinning and crocheting the fiber to an involved and excited crowd of individuals. I have had numerous positive interactions with kids which has made me realize that there is no group I would rather work with more.

Our family farm became close with the few farms that were around us. We would help the alpaca farm 20 minutes from us shear their alpacas, and we once helped a small farm repair its fence that had been ravaged by a tornado. It felt good to be able to help people with things that not everybody has the knowledge to do. The farm helped shape my view of community into one of empathy which encompasses the spirit of being a physician. The joy I received from helping other farms led me to pursue community service opportunities at my university which I found first with ASB, a community service organization in which students dedicate their spring breaks to participate in meaningful service activities, and later as an AmeriCorps volunteer. When I signed up for my first ASB trip in my freshman year, I looked for a trip that involved helping kids. I knew I loved working with the younger population by assisting my mom at her home daycare and those presentations we gave to special education classes. The trip that caught my attention was to Pulaski, VA, which worked with a service organization called Beans and Rice. We would do fulfilling tornado recovery work in the morning, but I most looked forward to afternoons where we got to sit down and chat with kids about their days while helping them with their homework. I heard many stories from the kids about going to bed hungry or their parents being out of work. We were able to sit with whomever we wished during the kids’ lunch which I primarily spent with Chase, a boy who the other kids saw as an outcast due to his sexual orientation. My time with these kids made me realize how some people did not grow up with the strong sense of community that I knew at their age and inspired me to continue my work with their age group.

During my time in Pulaski, the director of the organization recognized my passion for working with kids and encouraged me to apply to AmeriCorps. I found a program in Lincoln, NE which allowed me to work with impoverished kids and share my passion of science with them under my given alias of T-Roy the Science Boy (not to be confused with my rival, Bill Nye the Science Guy). My relationships with the children I was working with grew fast, but one student made a significant impact on me. The second-grader was incapable of paying attention to academics yet had an amazing sense of humor. On the surface, his apparent developmental issues brought on by fetal alcohol syndrome resulted in hyperactivity and an inclination for angry outbursts. I spent time with him every day but came to the realization that, no matter how many times I was able to help him understand something, it did little to help his underlying health problems. Going to medical school will allow me to obtain the knowledge and skills I need to offer the ultimate service to people like my second-grade student—access to a healthy life.

With a strong desire to continue giving back to my community, I signed up to be a patient advocate in Baystate Medical Center’s emergency room. Here I was exposed to different health issues and many upset family members. It was my job to ensure the patients and their families were as comfortable as possible, but my job often morphed into one of a storyteller conversing with the families to get their minds off their difficult situations. Of course, the alpacas were a common topic of discussion since kids always love seeing the goofy haircuts we give them. My mother made this an easy task by uploading a video of us shearing the alpacas onto YouTube titled “Spit Happens”. A fitting name, no doubt. I have been blessed to share my farm-inspired sense of community with a broad range of different cultures from Nebraska to Virginia. I look forward to travelling to new communities as a physician while keeping my community-driven morals close, so alpaca my bags now.

This author is unique in his excellent command of humor. Note that this is a riskier approach and most applicants should avoid humor. In this setting, the humor certainly adds value to the essay, although this may be more off-putting to more traditional and conservative medical school admissions committee members. Overall, a high risk and high reward strategy, because when it lands, it makes for a compelling, unique, and entertaining read. Remember, admissions committees are reading through thousands of essays, and this comes as a breath of fresh air.

The introduction is brilliantly engaging and humorous, and entices the reader for what is to come. Clearly, this author has an interesting story to share and isn’t afraid to make you laugh.

While the essay is overall good, it could be improved in a few notable ways. First, the sentence structure and word choice can be tightened up in areas. The reader may find themself having to reread more than one sentence to understand what the writer is hoping to convey. Secondly, while the author does a great job highlighting a very unique and wide ranging background, showing more than telling would increase the effectiveness of this essay. Additionally, more emphasis and attention on “why medicine” and “why you would make a good doctor” would make this medical school personal statement more universally appealing (and less risky).

It’s not every day you help a kid become Iron Man. It happened for me during an internship at the NIH. I was responsible for designing the electronics and software for a portable robotic exoskeleton to help children expressing crouch gait due to cerebral palsy to improve their gait by retraining their muscles and neuron pathways. I saw the project as a fascinating technical problem and immersed myself in solving it.

Then I met Isaiah. Isaiah is a child with cerebral palsy expressing crouch gait with limited mobility. When Isaiah first began training on the robot, he became frustrated. As I watched him become exasperated using the device, it really hit me that I was creating a device for a real person, and the way we delivered his care was every bit as important to what we were doing as delivering an effective technical solution. As his confidence grew, I witnessed Isaiah, who could barely walk without the device, try to run. We even had to tell him to slow down! He asked if he could bring home the device because it made him feel like Iron Man. This experience crystalized for me my calling, to solve the challenging medical problems children face with love and a deep appreciation for their humanity.

I have firsthand knowledge of what it means to a child with serious medical problems to have loving physicians and nurses. When I was four, I received a heart transplant. Five years later, I fell ill with Hodgkin’s Lymphoma. Throughout these difficult and uncertain times, I was fortunate to have a clinical team whose positivity and humor made me feel like a normal kid despite the fact that I was facing grave medical problems. While these experiences were difficult, they gave me a perspective that I treasure because it gives meaning to every day of my life. This perspective is where my calling originates – to become a physician-engineer completely committed to the emotional well-being of each of my patients.

The engineering problems many children face are substantial, and I am grateful for the opportunities I have been given to develop my skills in this area. As a part of the Center for Bioengineering Innovation & Design’s design team program I worked on two projects that taught me different aspects of the process of developing medical devices. The first project, NeoVate, gave me an overview of the design process of bringing medical devices to market. We developed a neonatal monitoring system for the developing world. We began with a needs assessment and then prototyped our solution to satisfy the specifications we developed. While I focused on the technical development, it was valuable to see other members create a sustainable distribution model because it helped me understand the step by step process by which an idea goes from concept to adoption in the medical field.

For the second project, TacPac, I was the team leader. On past teams I had a narrow focus on the technical development, but on TacPac I had to be knowledgeable about all aspects of the project and see the big picture in order to develop strategies to move the team forward. I learned how to create contingency plans by reaching out to our numerous advisors in many different specialties to build decision trees.

This project had an extra layer of meaning for me since we were developing an at-home monitoring system for tacrolimus, an immunosuppressant drug I have been taking for over twelve years. Currently, monitoring of this drug’s levels can only be done in a clinical setting. Our device allows patients to monitor their levels in the home, allowing for less inconvenience to patients and more data to make more informed clinical decisions.

While my engineering training developed my technical skills, the foundation of my heart and why I will pour myself into my vocation is derived from the love and care I received from my own clinical team as a child. I feel called to be of service to children with serious medical issues, just as my physicians and nurses were to me. One of my favorite volunteer experiences was when I was a camp counselor for Heart Camp, where I had previously been a camper. Heart Camp is a week-long camp for children with congenital heart defects designed to create an environment of fun, hope, and normalcy. This is one way in which I can use the difficult experiences of my childhood for good because it is easy for me to bring normalcy to these children’s lives since for me, it is normal.

Another volunteer opportunity that has had a tremendous amount of meaning for me is working with the Washington Regional Transplant Community to spread organ donation awareness by telling my story. Since I never received the chance to know my donor family, I use this volunteering as my way to say thank you.

I have enjoyed my engineering studies and my volunteering experiences have been of tremendous value to me, but I cannot wait to go to medical school. It is my desire to be a bridge between the technical engineering world and the direct delivery of care that only physicians can give. I feel it is my mission to use all of my experiences, both good and bad, to find innovative solutions to help the next Wonder Woman and Captain America thrive both physically and in every other part of their lives.

The superhero theme is unique, timely, and highly relevant to the author’s interest in pursuing a pediatric specialty. The author has a strong research background and ultimately was accepted to a highly ranked and research heavy institution, which is no surprise. While a significant portion of the body of the essay reads as “tell” more than “show”, some aspects of the personal statement use more effective story telling.

Deep interest in research, a unique background of being a lymphoma patient, and a palpable passion to help other kids who are suffering makes this applicant come across as a valuable asset to any research oriented medical school.

To further improve the impact of this essay, the author could remove one or two experiences listed in a more descriptive way and incorporate immersive stories to convey the significance and impact they had on him.

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Medical school personal statement examples.

Get accepted to your top choice medical school with your compelling essay.

THE TOP 10 MEDICAL SCHOOLS

HAVE AN AVERAGE ACCEPTANCE RATE OF 5.3%

A GREAT MEDICAL SCHOOL PERSONAL STATEMENT IS KEY IN THE APPLICATION PROCESS

If you want to get into the best school, you need to stand out from other applicants.  

U.S. News   reports the average medical school acceptance rate at the top 100 med schools at 6.35% , but our med school clients enjoy an 85% ACCEPTANCE RATE .

How can you separate yourself from the competition successfully? By creating a great personal statement.

body:nth-child(2) > div.body-wrapper > main:nth-child(3) > div:nth-child(1) > div:nth-child(1) > div:nth-child(1) > div:nth-child(1) > div.row-fluid-wrapper.row-depth-1.row-number-6 > div:nth-child(1) > div:nth-child(1) > div.row-fluid-wrapper.row-depth-1.row-number-7 > div:nth-child(1) > div:nth-child(1) > #hs_cos_wrapper_dnd_area-module-12 > #hs_cos_wrapper_dnd_area-module-12_ > h2:nth-child(2)">Medical School Sample Personal Statements and Essays

Here we present medical school personal statement examples to give you ideas for your own essay.

Pay close attention to the consistent format of these effective personal statements:

ENGAGING INTRODUCTION / UNIFYING THEME / COMPELLING CONCLUSION

Give the admissions committee readers a clear picture of you as an individual, a student, and a future medical professional. Make them want to meet you after they finish reading your essay.

Here's what you'll find on this page:

• How Sample Med School Essays Can Help You
• Before you Start Writing
• Writing Your Opening Paragraph
• Writing Your Body Paragraphs
• Writing Transitions
• Writing Your Conclusion
• Common Elements Between Personal Statements

Five Don'ts for Your Medical School Personal Statement

• Personal Statement Examples & Analysis
• Frequently Asked Questions

How can these sample med school essays help you?

You plan to become a physician, a highly respected professional who will have great responsibility over the health and well being of your future patients. How can you prove to the admissions committee that you have the intelligence, the maturity, the compassion, and the dedication needed to succeed in your goal? 

The medical school personal statement examples below are all arguments in favor of top med schools accepting these applicants. And they worked. The applicants who wrote these essays were all accepted to top medical schools - most to multiple schools. They show a variety of experiences and thought processes that all led to the same outcome. However, while the paths to this decision point vary widely, these winning essays share several things in common. 

As you read them, take note of how the stories are built sentence by sentence, paragraph by paragraph, adding to the evidence that the writer is worthy of acceptance. This evidence includes showing a sustained focus, mature self-reflection, and professional and educational experiences that have helped prepare the applicant to succeed. 

As you write your medical school personal statement , include your most compelling, memorable and meaningful experiences that are relevant to your decision to become a doctor. Each sentence should add to the reader’s understanding of who you are, what your strengths are, and why you will make an outstanding physician. Your resulting essay will help the adcom appreciate your intellectual and psychological strengths as well as your motivations, and conclude that you are worthy of acceptance into a top medical school. 

Techniques for creating successful medical school personal statements

Before you start writing your med school personal statement.

Before you start writing your medical school personal statement you will need to choose a topic that will reflect who you are and engage the reader. There are a few strong ways to proceed. Try freewriting with a few of the following topic ideas.

Why medicine? Do you have a personal experience that made you certain about being a physician? How, when, did you know this was the right career for you? Is there a doctor you know (or knew) who emulates an altruistic moral character, someone who won your deepest respect? Can you show this person in action or describe them as they model inherent qualities, those for which you will strive as a physician?

How has a clinical experience been a real growth moment for you? Can you tell that story? Sometimes a clinical experience is deeply personal, something experienced by you or by someone in your family. Sometimes a clinical experience is about a patient whose situation taught you something deeply valuable, something honestly insightful about what good care means, about humanity, about empathy, about compassion, about community, about advantage and disadvantage, about equity and inclusion. 

Choose an experience outside the comfort of your own community, an experience where you were the outsider (uncertain, facing ambiguity) and this experience brought about a fresh, resonant understanding of yourself and others, an understanding that made you grow as a person, and perhaps brought about humility or joy in light of this geographical or cultural dislocation. Often this prompt includes traveling to other countries. Yet, it could work just as beautifully discovering people in close places that were previously unfamiliar to you – the shelter in the next town over, a foster home for medically unstable children, the day you witnessed food insecurity firsthand at a local church and decided to do something about disparity.

Read other successful personal statements in guides and publications. You can read sample personal statements that work here: medical school personal statement examples

The prompts above have great possibilities to be successful because they locate experiences that require better than average human understanding and insight. When we re-convey a moving human experience well, we tell a story that aims to bring us together, unite us in our common humanity. Telling powerful stories about humanity, in the end, presents your deeper attributes to others and demonstrates your capacity to feel deeply about the human condition. 

Be careful how often you use the first person pronoun, though you may use it. Revise for clarity many more times than you might do in other writing moments. Choose precise vocabulary that sounds like you, and, of course, revise so that you present to your readers the most pristinely grammatical you. 

Once you’ve looked at the sample medical school personal statements in the link above, try freewriting again according to one of the themes listed that applies to you. For instance, perhaps your prior freewriting aimed to describe a moment in your life that seeded your interest in medicine. Great. Save that file. Now, start again with a different topic, perhaps one from the linked page of sample personal statements. For instance, let your freewriting explore the time you traveled to another country to participate in a public health mission. What person immediately comes to mind? Hopefully this person is quite different from you in identity and culture. Make sure this comes across. Describe the scene when you first encountered this person. What happened? Tell that story. Why do you think you remember this person so vividly? Did the experience challenge you? Did you learn something deeper and perhaps more complex about humanity, about culture, about your own assumptions about humanity? Hopefully, you grew from this experience. How did you grow? What do you now understand that you did not understand before having had this experience? Hindsight may very well bring about perspective that demonstrates that you now understand the value of that human encounter. 

Here is a cautionary bit of advice about writing about childhood. Yes, it is relatively common to have had a formidable experience in childhood about illness, health, healthcare, medicine or doctors. Right? Most of us have had at least one critical health issue in our own family when still a child. Sometimes it is absolutely true that a moment in childhood began your interest in healthcare. 

One may have had a diagnosis as a child that turned one’s life path toward being health-aware. For instance, are you a juvenile-onset, Type I diabetic? Do you have a cognitive or physical disability? Were you raised in a home with someone who had a critical illness or disability? Did a sibling, parent or grandparent get gravely sick when you were young? 

Upon writing-up any of these situations for your personal statement, there is a catch-22. For medical school application activities, the rule of thumb is “nothing from high school.” So why then is it sometimes a good idea to write about a childhood situation in a personal statement? The answer has to do with the uniqueness of your story and the quality of hindsight through which you narrate it.

Let us slow down for a moment on the issue of writing about childhood. Typically, traditional applicants to medical school are steadfastly dedicated to their academic and pre-professional aims. Science curriculum, especially pre-med curriculum, is demanding and rigorous, and it trains science students to excel in empirical thinking and assessment. 

Sometimes, when asked to write a personal essay, hard core science students feel the rug pulled out from under them. Are you more confident and meticulous about action steps and future plans than you are confident about being a sage looking back on your life? Chances are your answer is “yes.” 

Of course you can write; you’re a smart person and a very good student. Yet, writing a heartfelt, perceptive essay about yourself or an aspect of your life for an application to medical school is unnerving even as you understand why your application might benefit from story-telling. Yes, your application should benefit from your engaging, authorial presence in the essay. An application that lacks this is wholly at a disadvantage. 

Perhaps you are gravitating to the choice to share a story about your childhood. 

For instance, what if you sat down to free-write the following prompt:

Draft an essay about a childhood experience that ingrained medicine as one of your inherent interests. Do so in a manner that demonstrates the value of hindsight while telling it.

Is it hard to stay calm about this prompt right now even though this prompt is precisely what could make your personal statement successful? The idea of this prompt is what many successful applicants have written well, and you can too. Why not seek professional guidance for your personal essay? Accepted has consultants who advise applicants through this process. We advise you on the whole process of developing a successful idea for an essay, help you mine your experiences, outline your strongest ideas, and after you’ve written them up, edit your drafts. You can view these personal statement services here: Essay Package

Back to tips. The key to writing a personal statement that frames a moment in childhood well is to stand firmly in the present and stay descriptive and perceptive. Write up that experience trusting you have insight. Quite a bit of time has passed since then, and that distance has given you the opportunity to see things a little differently now. 

Let’s presume you want to write about how as a child you had an older sibling with a cognitive impairment. You and your family witnessed time and again doors being shut, so to speak, on his ability to be included in school events or community events.

Free writing A: My older brother, G, had moderate cognitive impairment. He was never given field time in soccer games. When this happened, G cried. When this happened, I cried and felt hurt by how much time my parents spent trying to calm him down, eventually leaving the field, holding him close and bringing us back home, another Saturday wrecked. 

Example A has no benefit of hindsight.

Free writing B (with some hindsight): My older brother, G, had moderate cognitive impairment. Most of the time, kids were kind to him. “Hey G, how are you, man?,” they would say and high-five him. Most kids greeted him, offered him snacks and a seat on the sideline blanket. It was touching to see him included and seen at soccer games.

Further hindsight: G was rarely played in the game. 

Reflective comment: No harm would have been done in letting him play. It’s clear to me now how much more work we each need to do about inclusion. Community-based team sports are pretty good about extending kindness at the sidelines, but that is not the same thing as letting all kids play in the game. I am still grateful for every kindness extended to my brother, but perhaps letting him play in the game would have demonstrated to kids and parents alike a deeper message about the importance of inclusion over winning. The coaches meant no harm, but that is precisely how unconscious bias plays. Afterall, community by its very definition is about inclusion.

Standing tall on this matter brings out a maturity and vocabulary to master this kind of personal writing that Free Writing A lacks. You don’t want to go back in time and join your younger self and narrate from that perspective. The “return” to your former child typically results in replicating a childlike emotional capacity – and chances are, that’s not you anymore. You’ve seen more. You’ve grown more. You’re now formally educated. You’re more skilled at making connections between ideas and experiences. You can narrate a scene or circumstance and attach awareness of what you realize now it means – like the over-narratives of documentaries where the author sheds true insight about the meaning of past events. 

Most traditional applicants to medical school are just a few years older than teenagers. 

When hindsight brings great clarity and insight to the significance of an experience, we demonstrate a keener maturity and an understanding that in authoring an experience we have a responsibility to demonstrate how a personal experience becomes a valuable portal to understanding the situation of others. Hindsight done well can be a stunningly beautiful and engaging narrative skill.

Perhaps you would rather write about a clinical experience? If you write about patients, change names, change gender, change some context to assure anonymity. Nearly all healthcare workers are concerned about telling patient stories because we worry about appropriating someone else’s experience, or feel we may not have the right, literally since HIPAA set rules on patients’ privacy rights in 1996. We should be concerned about telling patients’ stories; however, how we tell them is key in honoring them. When we honor patients and convey their stories to others we demonstrate the reciprocity of the professional relationship. Physicians no longer have a prescriptive, patrician role. Physicians are no longer sole authorities. Physicians and patients establish a reciprocal relationship, a two way street wherein a physician steps into a space of illness with the patient and walks with them, with the goal of healing, curing and advocating for them. When doctors tell stories, they establish that patients matter, that these encounters matter, that doctors think about patients and often learn from them. 

How we write patient stories is best done humbly, of course. We can narrate a story that becomes exemplary for its insight and empathy – after all, insight and empathy are desirable traits of a physician. Be sure to show rather than tell, most of the time. Be sure to capture the sensory detail of people and place. For instance, is the patient sitting on a blue plastic chair under ultraviolet lights in the waiting room of a free clinic? Is a woman with her gray hair twisted in a bun wearing a cotton hospital gown, waiting against a concrete wall in a tiny examination room with the door open? (Setting makes a character more real.) 

Finally, your story perspective, what you see and understand, becomes another way of revealing who you are. 

How to write your opening paragraph:

A strong opening paragraph for a story begins “several pages in.” A strong story begins with you, the narrator, already standing in the ocean with water splashing at your knees. This is called a hook: “D began to bleed after the second attempt to start an intravenous line.” 

Then, get the basic narrative facts down, the 5 W’s, the who, what, where, when and why, so your readers will not be confused: “She was a patient in the infusion clinic in the cancer pavilion of a major Boston hospital. She came to the clinic for her first round of chemotherapy.”

What else about this moment engaged you? Did D come to her appointment alone via an Uber ride? Why wasn’t anyone with her? How did that make you feel? Did the two of you hold a conversation while you were trying to start an IV? Why do you think she started to bleed? How did she respond when she saw you were having trouble starting this IV? Why didn’t she have a Medi-port yet? Here, you are building fuller context for her story. Don’t race through the scene; rather, build it, slowing down time, using images and sensory details to “paint” with your words. Smaller details, necessary ones, help you portray D as an individual. 

“Semper Fidelis was tattooed on her forearm. ‘Thank you for your service,’ I said.” 

“‘This cancer thing,’ she said, ‘this is nothing.’”

“D’s comment set me back. She had triple-negative breast cancer. She had blood running down her arm to her hand, between her fingers and onto a stiff, white pillow case on which she rested her arm. Triple-negative breast cancer was much more than nothing. In fact, it was very serious.” 

What questions came to mind that provide several ways of reading this moment? Write them down. For instance,

• Did D not know about the gravity of her diagnosis?
• Was she steely and tough yet informed?
• Did she live through something much worse while enlisted as a Marine?

The questions themselves may wander too much to serve your personal statement as a succinct essay, which it needs to be. However, the answers to those questions may be exactly the additional content you need to develop this story’s acumen and perception as you demonstrate how getting to know the patient is a critical skill in order to help her. And now a theme is starting to come through: a doctor treats a patient, not a diagnosis. Voilà!

Moving forward: How does a doctor reframe clinical assumptions in this instance? What does a future doctor learn from a circumstance like this? 

Notice in the example above that the writing is active, uses details, and vivid language.

This writer has a palpable connection to the moment. One key to choosing one experience over another for your personal statement is how visual and vivid your recollection is. Often, moments worth mining for meaning are easy to recollect because they still have unresolved messages that need to be understood. Writing experiences helps us find their meaning, their sense. 

Notice as well, the scene above captures a moment of ambiguity, a concept particularly difficult for many health science professionals to embrace because there are multiple ways of looking at and understanding something. Stories send empiricism into the wind. People are not solely empirical. There is the self that is the body, which can be understood empirically, but there’s also the self that inhabits the body, the thinking/feeling/being and perceiving self. Stories are not about right answers. Stories attend to sentience and explore humanity. Patients’ lives are rife with uncertain moments, uncertain decisions, uncertain treatments, uncertain consequences, and uncertain outcomes. How does a physician engage with health uncertainty, understand it, and navigate it through pathways of humanity rather than pathways of diagnosis?

How does health care challenge you to grow in humanistic ways?

How to write your body paragraphs:

Once you have written a compelling scene, it might be a good idea to reflect upon why you were drawn to write about this experience in particular before your proceed. How does this scene illustrate meaningfully something worth explaining about becoming a physician? For instance, D’s scene was illustrative of an unexpected shift in perception that mattered when treating a patient with a serious cancer diagnosis. This unexpected shift happened to you, not to her. D’s been living with herself aplenty. Her point of view surprised you, not her, and reveals an incongruence between her perspective on her illness and yours.

Brief moments of ambiguity like this one can make us talk to each other, make us want to do something, can bring us to explore some further niche, specialty or research. Perhaps D brought you to peruse PubMed to research “Issues in Clinical Practice when Caring for Veterans” to see if you could find articles to help you help D and other veterans. Perhaps D’s comment was so truthful that you now volunteer with a veterans’ organization to scribe their stories for a war history museum? This “call to action” is a worthy story in a personal statement. Tell D’s story and conclude it with empathy and action. (Taking action to help is a demonstration of empathy.) Mindfully showing the experience with D as a catalyst to a path of action to help those under duress -- in distress, in crisis, or adrift in inequity -- matters.

Perhaps, follow this conclusion with a brief explanation of what principles now guide your humanistic path to medical school as long as they are principles that matter to your choice schools. 

Here are a few things to avoid in writing your medical school personal statement. Avoid talking about your scholastic path in preparation for medical school in your essay. The essay is not a place to reiterate scholastic achievements, for instance, a high GPA, academic honors, academic awards, publications, or MCAT scores because they’re front and center in other areas of your application. 

Instead, frame your medical school personal statement around a formidable experience that directly or indirectly led you to pursue medicine. This could be a struggle that you’ve overcome that demonstrates your fortitude (the story of a sociocultural disadvantage or disability), the first time you deeply understood the ramifications of health care disparities you will not forget. Likely, this would be a personal story about yourself or a family member, a clinical story or a mission trip, or a story about a patient from some other volunteer work that you’ve done. 

Additional topic ideas for your personal statement: What is a successful doctor? What does a successful life as a doctor look like? What happens to your understanding of best practices when a patient’s situation makes a best practice unrealistic, and what is the remedy? What epiphany, small or large, resides in you now since having mined a critical, clinical experience? Do you see a difference in the way you respond to patients since having had this experience? How has clinical experience matured you, deepened your awareness of living? If a patient experience became a catalyst for you to branch out or deepen your healthcare exposure opportunities, talk about that too. What opportunities? Why?

Writing effective transitions:

You are now ready to proceed to a conclusion that leaves your readers, the admissions committee, with a lasting impression of you – your life, your mind, your character -- as a 21 st century physician. 

Chances are, you’ll need to transition from the previous discussion of a time in the past to squarely speak about yourself here and now or in a comment toward the future. 

Can you sum up your main idea for the past experience? Consider the benefit of using a word or phrase -- thus, just as, hence, accordingly, in the same way, correspondingly -- and present your central idea again but only in a few repetitive words (called parallelism) or with synonymous words, creating internal unity in the essay. 

Be careful how you do this. The phrasing should feel necessary and fluid rather than reductive or even worse, phrasing that sounds like filler. 

The shift you’re making is from then to now, or from then to now and to the future as in “all this is to say.” Would you benefit from a fact, a quote, a statistic, or an informed prediction on the state of medicine, public health, or the future of medicine? 

Grammar tips: 

Transitional words can indicate:

• a process: first, second, next, finally…
• time: by lunch time, that evening, two weeks later…
• spatial sequences: down the block, two miles west, one bed over…
• logic sequences: likewise, however, evidently, in other words…
• meta-thought: as I say this, looking back, I have nothing left to say…

If grammar and idea flow are a concern, have a look at Accepted’s editing services: Med School Essay Package

A consultant will walk you through the inception of an essay, an outline, and editing from first through final drafts, including suggestions for idea development and transitions from one idea to another.

How to write your conclusion:

A strong conclusion for your medical school personal statement can highlight the relevance of a timely issue (for instance, the physician shortage in the U.S.), make broader inferences about something you’ve already discussed (for instance, the broader implications of a particular health care disparity), or a call to action that you now embrace (for instance, community-based work that you did during the pandemic that now has become a central interest). Altruism, or understanding another’s disadvantaged situation, should not be represented in your conclusion as “ideas alone.” Commitment to serve others is not solely aspirational (“As physicians, we must do everything we can about inequity"), but a strong conclusion puts ideals into action (“I have joined Dr. T’s research team to conduct qualitative research about how social strata paradigms impact health care inequity”). Action in the conclusion should be associated with an experience shown earlier in the essay and culminate as a demonstration that you have already begun shaping your path in medicine. You are not waiting to begin but have already begun facing the challenges and responsibilities of future physicians. This kind of conclusion shows vision, maturity, commitment and character.

If the story in the body of your personal statement is about an experience, the conclusion should show your growth since then and keep in alignment how you’ve grown with the medical school values and missions of the majority of schools on your list. So, if you’re applying to top-tier allopathic schools, your growth may be in the depth and orientation of your recent research, or in having established a tighter link between your clinical experience and research. 

If you’re applying to osteopathic schools, your growth should be in keeping with the osteopathic schools’ values and missions on your list and include recent hands-on experience, something with specific tasks and responsibilities, rather than shadowing, since shadowing is often seen as passive experience. It may be that you’ve become a licensed EMT and will work as an EMT in a relevant region or state during the gap year. It may be that you’ve been certified and now work as a harm reduction specialist for a particular organization in a particular city or county. 

If you’re applying to both allopathic and osteopathic schools, each personal statement should align with the academic orientation of each pathway. Using the same personal statement for both AMCAS and AACOMAS applications is rarely a good idea. 

Accepted offers help with the whole application process: Primary Application Package

Other elements that each essay below have in common:

Accepted provides sample medical school personal statements with titles classifying types of narratives that have potential for success. Applicants do have some freedom of choice in what topic will serve their essay best. Why only “some” freedom in topic for this personal essay? Because this essay is one tool you will use to reach a professional goal. 

Not all essays help us reach professional goals. Writers of effective essays must take into account who will read them. Think about who your audience is. In this case, it’s a medical school admissions committee – not a friend, not a parent, not a peer. How will you write an essay on the same topic, let’s say a lab experience that went from bad to revelatory? You’d tell this story quite differently to your lab mates than you would to your professor, than you would to the president of your university, than you would in a grant application. 

Here’s what can happen when the “audience” isn’t considered sufficiently when writing about a passion. Let’s say you love playing soccer, and played on a Division 3 team as an undergraduate. Let’s say it didn’t matter to you that the team was Division 3 as long as it meant you could get on the field and play through your undergraduate years. It’s quite possible that one can write well about playing soccer, but one must do so in such a way that the reader really believes and understands the parallel between doing what you love and a future in medicine. Otherwise, the writer may very well convey that they love soccer. However, when written without the focus that medical school admissions committees will be readers, the essay could end up conveying that the narrator really wants to be a soccer coach, not a doctor. 

So, there’s only some freedom in topic and some freedom in writing approach - and the two must make sense together in order to facilitate accomplishing your goal. 

There is no “one-size-fits-all” to writing a successful medical school personal statement. There are, however, aspects to the sample essays on this site that stand out. 

First, each personal statement example is authored by someone who knows exactly what story they’re telling. No matter what their first draft looked like, by the time the final draft is ready to go, all fuzzy draft moments have been made lucid and engaging. All sections of the essay should have the polish and the same goals. 

• Why am I telling this in this way? 
• To what ends does each scene or moment speak?
• Have I revised enough to make every sentence demonstrate strong writing skills?

Each sample personal statement emphasizes narrative control, engages with a direct voice, has conclusive things to show and say, demonstrates logical steps in idea development, and presents effective framing of the composition as a well-written form that displays strong writing skills. 

Even when an essay includes a “bookend” structure (a narrative structure that begins and ends with X, with middle content about Y), the story of Y (i.e. a mission trip in Mexico) is the primary story framed by the X bookend story (i.e. the love of running) to give ballast to the context in which this writer wants us to understand the mission trip as well, as a parallel story of challenge, commitment, exhilaration, exhaustion and necessity.

The same is true for stories that contain contrasts. If you’ve traveled ten mile or ten thousand miles, it is quite possible you’ve encountered different assumptions than your own about health care, health care access, trust, understanding of middle-class or first-world beliefs about health, understanding beliefs from poor and disadvantaged communities, illness, health care in contrast with a different cultural standard than what you’re used to, different beliefs about health care access, and a lack of or cautious trust in deference to doctors. (See the “Nontraditional Applicant” and “The Traveler.”) The key to this kind of essay is first demonstrating the contrasts between the two realities (yours and the patient’s reality) and their relative assumptions. Second, demonstrate an understanding of beliefs amid the two experiences and aim to reconcile their adverse assumptions.

However you proceed with the paragraph by paragraph progression of your medical school personal statement, be sure to see how there’s deeper intuition or knowledge associated with how the ideas progress. Do not repeat yourself, or reiterate a statement or idea unless you are clearly doing so for rhetorical emphasis.

Then, kiss your draft goodnight. Let it sit for two or three days, and return to it time and again with fresh eyes – to trim, tighten, clarify, improve tone and intention, and importantly, to make sure you have direct regard for your audience, who it is, what they’re looking for, and how you are the person whom they seek, as you maintain a tone and direction consistent with your goals and what you’re seeking from an admissions committee. 

Many students focus on their own or family members’ medical conditions in their personal statements. The essay sometimes reads like a medical history. Taking this approach can hurt your application for several reasons: It may alert them to conditions that could impact your ability to perform in medical school,   indicate that you lack boundaries by oversharing , or suggest a lack of maturity in focusing only on yourself and family – rather than on helping others or serving the community.

Anything you share in your personal statement can be brought up in your interview. If you share details of painful events, losses, or failures that you have not yet processed or come to terms with, that disclosure could come across as an invitation for the reader to pity you. Accepting long-term changes in our lives transforms us; we are constantly evolving through our experiences. Until you have integrated this information into your identity, depending on how impactful it was, you may not be able to use the experience to shed insight on yourself quite yet. Use negative experiences that are at least a year or older depending on how long it takes you to process and reflect. Most importantly,   use them to show growth and resilience , not to create pity.

• DON’T demonstrate a lack of compassion or empathy. One of the creepiest essays I’ve ever read – it still sends shivers down my spine just thinking about it – was a student’s description of how much she enjoyed anesthetizing and removing the brains of mice. Her intention was to share her love of science, research, and learning but the feverish glee with which she described these procedures lacked compassion for the creatures that lost their lives for her research project. This lack of respect for the sacredness of life made it an easy decision to reject her application. Research was probably a better path for her, especially since she wasn’t able to gauge the reaction her statements would have on her audience.
• DON’T bargain. The least fun essays to read are those that contain more promises than a politician’s speech. They include statements like, “If accepted into this program, I will….” The best predictor of future behavior is past behavior. If you really want to demonstrate what you are capable of achieving during your medical education,  give examples of what you have already accomplished . This approach is far stronger than making hollow promises.
• DON’T complain. Criticizing or pointing out the failures of healthcare professionals who have treated you or whom you have observed in the past will only reflect negatively on you. Since your application will be reviewed by doctors, as well as admissions professionals, it’s critical that you do not insult those from whom you are seeking acceptance. While it is true that medical mistakes and lack of access to care have devastating consequences for patients, their families and communities, identifying ways to improve in these areas without pointing any fingers would be more effective. By demonstrating your realistic knowledge of patient needs and sharing potential solutions, you can present yourself as an asset to their team.

Be careful what you write. Create a personal statement that is honest (not bitter), reveals your personality (not your medical history), and delivers a compelling explanation for your motivations for entering medicine (not empty promises). 

Do you want our expert advice on your medical school personal statement?

Med School Personal Statement Consultant Dr. Mary Mahoney

Med School Personal Statement Examples and Analysis

Now let’s explore what you can learn from some of these outstanding sample med school essays.

Medical school personal statement example  #1: Emergency 911 

“Call 911!” I shouted to my friend as I sprinted down the street. The young Caucasian male had been thrown fifteen yards from the site of impact and surprisingly was still conscious upon my arrival. “My name is Michael. Can you tell me your name?” In his late twenties, he gasped in response as his eyes searched desperately in every direction for help, for comfort, for assurance, for loved ones, for death, until his eyes met mine. “Flail chest,” I thought to myself as I unbuttoned his shirt and placed my backpack upon his right side. “Pulse 98, respiration 28 short and quick. Help is on the way. Hang in there, buddy,” I urged.

After assessing the patient, the gravity of the situation struck me into sobriety. The adrenaline was no longer running through my veins — this was real. His right leg was mangled with a compound fracture; his left leg was also obviously broken. The tow-truck that had hit him looked as though it had run into a telephone pole. Traffic had ceased on the six-lane road, and a large crowd had gathered. However, no one was by my side to help. “Get me some blankets from that motel!” I yelled to a bystander and three people immediately fled. I was in charge.

But my patient was no longer conscious; his pulse was faint and respiration was low. “Stay with me, man!” I yelled. “15 to 1, 15 to 1,” I thought as I rehearsed CPR in my mind. Suddenly he stopped breathing. Without hesitation, I removed my T-shirt and created a makeshift barrier between his mouth and mine through which I proceeded to administer two breaths. No response. And furthermore, there was no pulse. I began CPR. I continued for approximately five minutes until the paramedics arrived, but it was too late. I had lost my first patient.

Medicine. I had always imagined it as saving lives, curing ailments, alleviating pain, overall making life better for everyone. However, as I watched the paramedics pull the sheets over the victim’s head, I began to tremble. I had learned my first lesson of medicine: for all its power, medicine cannot always prevail. I had experienced one of the most disheartening and demoralizing aspects of medicine and faced it. I also demonstrated then that I know how to cope with a life-and-death emergency with confidence, a confidence instilled in me by my certification as an Emergency Medical Technician, a confidence that I had the ability to take charge of a desperate situation and help someone in critical need. This pivotal incident confirmed my decision to pursue medicine as a career. 

Of course healing, curing, and saving is much more rewarding than trying and failing. As an EMT I was exposed to these satisfying aspects of medicine in a setting very new to me — urban medicine. I spent most of a summer doing ride-alongs with the Ambulance Company in Houston. Every call we received dealt with Latino patients either speaking only Spanish or very little broken English. I suddenly realized the importance of understanding a foreign culture and language in the practice of medicine, particularly when serving an underserved majority. In transporting patients from the field to the hospitals I saw the community’s reduced access to medical care due to a lack of physicians able to communicate with and understand their patients. I decided to minor in Spanish. Having almost completed my minor, I have not only expanded my academic horizons, I have gained a cultural awareness I feel is indispensable in today’s diverse society.

Throughout my undergraduate years at Berkeley I have combined my scientific interests with my passion for the Hispanic culture and language. I have even blended the two with my interests in medicine. During my sophomore year I volunteered at a medical clinic in the rural town of Chacala, Mexico. In Mexico for one month, I shadowed a doctor in the clinic and was concurrently enrolled in classes for medical Spanish. It was in Chacala, hundreds of miles away from home, that I witnessed medicine practiced as I imagined it should be. Seeing the doctor treat his patients with skill and compassion as fellow human beings rather than simply diseases to be outsmarted, I realized he was truly helping the people of Chacala in a manner unique to medicine. Fascinated by this exposure to clinical medicine, I saw medicine’s ability to make a difference in people’s lives. For me the disciplines of Spanish and science have become inseparable, and I plan to pursue a career in urban medicine that allows me to integrate them.

Having seen medicine’s different sides, I view this as a multifaceted profession. I have witnessed its power as a healing agent in rural Chacala, and I have seen its weakness when I met death face-to-face as an EMT. Inspired by the Latino community of Houston, I realize the benefits of viewing it from a holistic, culturally aware perspective. And whatever the outcome of the cry "Call 911!" I look forward as a physician to experiencing the satisfaction of saving lives, curing ailments, alleviating pain, and overall making life better for my patients.

Lessons From Med School Sample Essay #1: Emergency 911

This essay is one of our favorites. The applicant tells a story and weaves a lot of information into it about his background and interests. Note how the lead grabs one’s attention and the conclusion ties everything together.

What makes this essay work?

• A dramatic opening paragraph

This essay has an unusually long opener, but not only is it dramatic, it also lays out the high-stakes situation of the writer desperately trying to save the life of a young man. As an EMT, the writer is safe in sharing so much detail, because they establish their bona fides as medically knowledgeable. With the urgent opening sentence (“Call 911!”) and the sad final sentence (“I had lost my first patient.”), the writer bookends a particularly transformative experience, one that confirmed their goal of becoming a doctor.  

• A consistent theme

The theme of a med school essay in which the applicant first deals with the inevitable reality of seeing a patient die can become hackneyed through overuse. This essay is saved from that fate because after acknowledging the pain of this reality check, the writer reports that they immediately committed to expanding his knowledge and skills to better serve the local Hispanic community. While not an extraordinary story for an EMT, the substance, self-awareness, and focus the writer brings to the topic makes it a compelling read.

• Evidence supporting the stated goal

This applicant is already a certified EMT, which serves as evidence of their serious interest in a medical career. In going on ambulance ride-alongs, the writer realized the barrier in communication between many doctors and their Spanish-speaking patients, which inspired the writer to take steps to both learn medical Spanish and shadow a doctor in a Mexican clinic. These concrete steps affirm that the applicant has serious intent.

Medical School Personal Statement Example #2: The Traveler

"On the first day that I walked into the Church Nursing Home, I was unsure of what to expect. A jumble of questions ran through my mind simultaneously: Is this the right job for me? Will I be capable of aiding the elderly residents? Will I enjoy what I do? A couple of hours later, these questions were largely forgotten as I slowly cut chicken pieces and fed them to Frau Meyer. Soon afterwards, I was strolling through the garden with Herr Schmidt, listening to him tell of his tour of duty in World War II. By the end of the day, I realized how much I enjoyed the whole experience and at the same time smiled at the irony of it all. I needed to travel to Heidelberg, Germany, to confirm my interest in clinical medicine.

Experiences like my volunteer work in the German nursing home illustrate the decisive role travel has played in my life. For instance, I had volunteered at a local hospital in New York but was not satisfied. Dreams of watching doctors in the ER or obstetricians in the maternity ward were soon replaced with the reality of carrying urine and feces samples to the lab. With virtually no patient contact, my exposure to clinical medicine in this setting was unenlightening and uninspiring. However, in Heidelberg, despite the fact that I frequently change diapers for the incontinent and deal with occasionally cantankerous elderly, I love my twice-weekly visits to the nursing home. Here, I feel that I am needed and wanted. That rewarding feeling of fulfillment attracts me to the practice of medicine.

My year abroad in Germany also enriched and diversified my experience with research. Although I had a tremendously valuable exposure to research as a summer intern investigating chemotherapeutic resistance in human carcinomas, I found disconcerting the constant cost-benefit analysis required in applied biomedical research. In contrast, my work at the University of Heidelberg gave me a broader view of basic research and demonstrated how it can expand knowledge – even without the promise of immediate profit. I am currently attempting to characterize the role of an enzyme during neural development. Even though the benefit of such research is not yet apparent, it will ultimately contribute to a vast body of information which will further medical science.

My different reactions to research and medicine just exemplify the intrinsically broadening impact of travel. For example, on a recent trip to Egypt, I visited a small village on the banks of the Nile. This impoverished hamlet boasted a large textile factory in its center where many children worked in clean, bright, and cheerful conditions weaving carpets and rugs. After a discussion with the foreman of the plant, I discovered that the children of the village learned trades at a young age to prepare them to enter the job market and to support their families. If I had just heard about this factory, I would have recoiled in horror with visions of sweatshops running through my head. However, watching the skill and precision each child displayed, in addition to his or her endless creativity, soon made me realize that it is impossible to judge this country’s attempts to deal with its poverty using American standards and experience.

Travel has not only had a formative and decisive impact on my decision to pursue a career in medicine, it has also broadened my horizons – whether in a prosperous city on the Rhine or an impoverished village on the Nile. In dealing with patients or addressing research puzzles, I intend to bring the inquiring mind fostered in school, lab, and volunteer experiences. But above all, I intend to bring the open mind formed through travel.

Lessons From Medical School Sample Essay #2: The Traveler

No boring repetition of itinerary from this seasoned traveler! This student ties their travels to their medical ambitions through the effective use of short anecdotes and vivid images. Can you sense the writer’s youthful disappointment during early clinical experiences and mature satisfaction working in the retirement home?

This applicant effectively links the expansive benefits of travel to their medical ambitions. By sharing vivid anecdotes from and reflections on these experiences, the writer enables the reader to easily imagine them as a talented physician in the future.

• An engaging opening that frames the storyline Many fine application essays open with imagery so vibrant that the writing could be mistaken for fiction. This essay is no different. We meet the writer in the setting of a nursing home overseas, where they question whether their volunteer experiences there will help them determine their career path. Notice how the first sentence reflects a worry, “I was unsure of what to expect,” but by the final sentence, the writer concludes with satisfaction, “I needed to travel to Heidelberg, Germany, to confirm my interest in clinical medicine.” With this framing, we appreciate the essay’s theme.
• Reflections on and contrasts about varied experiences in medicine The writer’s reactions to various encounters reveal a maturing mind-set: the “unenlightening and uninspiring” experience volunteering in a New York hospital versus the feeling of being “needed and wanted” in the nursing home in Heidelberg; the “disconcerting . . . constant cost-benefit analysis required in applied biomedical research” versus the “broader view of basic research and . . . how it can expand knowledge – even without the promise of immediate profit” at the University of Heidelberg. These reflections demonstrate a thoughtfulness born of experience.
• How traveling has expanded his potential as a physician Of the five tightly constructed paragraphs in this substantial essay, the final two paragraphs home in on how travel has had an “intrinsically broadening impact” and stimulated an “open mind” to people and situations. This kind of sophisticated view is a desirable trait to adcoms.
• Out-of-the-box theme Although this essay’s foundation is built on the writer’s sincere and dedicated aspirations for a medical career, they allowed themselves the space to write about the broadening intellectual benefits of travel, linking those benefits to professional potential. Even when writing about children working in a factory in Egypt, this applicant brings an expanded mind-set and greater cross-cultural understanding that will no doubt benefit them in their career.

Medical School Personal Statement Example #3: The Non-Traditional Applicant

"Modest one-room houses lay scattered across the desert landscape, their rooftops a seemingly helpless shield against the intense heat generated by the mid-July sun. The steel security bars that guarded the windows and doors of every house seemed to belie the large welcome sign at the entrance to the ABC Indian Reservation. As a young civil engineer employed by the U.S. Army Corps of Engineers, I was far removed from my cubicle in downtown Los Angeles.

However, I felt I was well-prepared to conduct my first project proposal. The project involved a $500,000 repair of an earthen levee surrounding an active Native American burial site. A fairly inexpensive and straightforward job by federal standards, but nonetheless, I could hardly contain my excitement. Strict federal construction guidelines laden with a generous portion of technical jargon danced through my head as I stepped up to the podium to greet the twelve tribal council members. My premature confidence quickly disappeared as they confronted me with a troubled ancient gaze. Their faces revealed centuries of distrust and broken government promises.

Suddenly, from a design based solely upon abstract engineering principles, an additional human dimension emerged – one for which I had not prepared. The calculations I had crunched over the past several months and the abstract engineering principles simply no longer applied. Their potential impact on this community was clearly evident in the faces before me. With perspiration forming on my brow, I decided I would need to take a new approach to salvage this meeting. So I discarded my rehearsed speech, stepped out from behind the safety of the podium, and began to solicit the council members’ questions and concerns. By the end of the afternoon, our efforts to establish a cooperative working relationship had resulted in a distinct shift in the mood of the meeting. Although I am not saying we erased centuries of mistrust in a single day, I feel certain our steps towards improved relations and trust produced a successful project.

I found this opportunity to humanize my engineering project both personally and professionally rewarding. Unfortunately, experiences like it were not common. I realized early in my career that I needed a profession where I could more frequently incorporate human interaction and my interests in science. After two years of working as a civil engineer, I enrolled in night school to explore a medical career and test my aptitude for pre-medical classes. I found my classes fascinating and became a more effective student. Today, I am proud of the 3.7 GPA I have achieved in competitive post-baccalaureate courses such as organic chemistry, biochemistry, and genetics.

Confident of my ability to succeed in the classroom, I proceeded to volunteer in the Preceptorship Program at the Los Angeles County/University of Southern California Medical Center. I acquired an understanding of the emotional demands and time commitment required of physicians by watching them schedule their personal lives around the needs of their patients. I also soon observed that the rewards of medicine stem from serving the needs of these same patients. I too found it personally gratifying to provide individuals with emotional support by holding an elderly woman’s hand as a physician drew a blood sample or befriending frightened patients with a smile and conversation.

To test my aptitude for a medical career further, I began a research project under the supervision of Dr. John Doe from the Orthopedic Department at Big University. The focus of my study was to determine the fate of abstracts presented at the American Society for Surgery of the Hand annual meeting. As primary author, I reported the results in an article for the Journal of Hand Surgery, a peer-reviewed publication. My contribution to medicine, albeit small, gave me much satisfaction. In the future, I would like to pursue an active role in scientific research.

My preparation for a career as a medical doctor started with my work as a professional engineer. From my experiences at the ABC Indian Reservation, I realized I need more direct personal interaction than engineering offers. The rewarding experiences I have had in my research, my volunteer work at the Los Angeles County Hospital, and my post-bac studies have focused my energies and prepared me for the new challenges and responsibilities that lie ahead in medicine."

Lessons From Med School Sample Essay #3: The Non-Traditional Applicant

Here, an older applicant takes advantage of their experience and maturity. Note how this engineer demonstrates their sensitivity and addresses possible stereotypes about engineers’ lack of communications skills.

What works well in this essay?

• A compelling lead This story begins in a hot desert landscape, an unexpected and dramatic starting point. Can’t you just feel the heat and sense the loneliness of the remote Indian reservation? Equally powerful in this first paragraph is when the writer faces the need to suddenly and completely rethink their carefully planned approach to address the tribal leaders. Their excitement is dashed. Their confidence has plummeted. They are totally unprepared for the mistrust facing them and their plan, and they need to improvise –quickly. Who wouldn’t want to read on to see how they resolve this dramatic turn of events?
• Solid storytelling that leads to a satisfying conclusion This nontraditional med school applicant reinvents themself in this essay. After realizing that they want more human involvement and interaction in their work, they take this self-knowledge and show us the steps they took to achieve their new goal. The steps are logical and well thought out, so the writer’s conclusion that they are well prepared in every way for med school makes perfect sense.
• Evidence to support their theme Through taking prerequisite courses in medicine (and achieving high grades) to bedside hospital volunteering (which provides emotional satisfaction) to helping write a medical research paper (which provides a feeling that they are making a meaningful contribution), the writer offers evidence that they are well suited for their new goal of a career in medicine. Each experience shared is relevant to the writer’s story. Any reader will agree that the applicant’s future as a physician is promising.
• A thoughtful perspective From the opening paragraph, the writer shows their ability to adapt to new situations and realities with quick thinking and psychological openness. They assess each stage of their journey, testing it for intellectual value and emotional satisfaction. Journeys of reflective self-discovery are something adcoms value.

Medical School Personal Statement Example #4: The Anthropology Student

"Crayfish tails in tarragon butter, galantine of rabbit with foie gras, oxtail in red wine, and apple tartelettes. The patient had this rich meal and complained of “liver upset” (crise de foie). Why a liver ache? I always associate indigestion with a stomach ache. In studying French culture in my Evolutionary Psychology class, I learned that when experiencing discomfort after a rich meal, the French assume their liver is the culprit. Understanding and dealing with the minor – sometimes major – cultural differences is a necessity in our shrinking world and diverse American society. Anthropology has prepared me to effectively communicate with an ethnically diverse population. My science classes, research, and clinical experience have prepared me to meet the demands of medical school.

I first became aware of the valuable service that physicians provide when I observed my father, a surgeon, working in his office. I gained practical experience assisting him and his staff perform various procedures in his outpatient center. This exposure increased my admiration for the restorative, technological, and artistic aspects of surgery. I also saw that the application of medical knowledge was most effective when combined with compassion and empathy from the health care provider.

While admiring my father’s role as a head and neck surgeon helping people after severe accidents, I also found a way to help those suffering from debilitating ailments. Working as a certified physical trainer, I became aware of the powerful recuperative effects of exercise. I was able to apply this knowledge in the case of Sharon, a 43-year-old client suffering from lupus. She reported a 200% increase in her strength tests after I trained her. This meant she could once again perform simple tasks like carrying groceries into her house. Unfortunately, this glimpse of improvement was followed by a further deterioration in her condition. On one occasion, she broke down and cried about her declining health and growing fears. It was then that I learned no physical prowess or application of kinesiology would alleviate her pain. I helped reduce her anxiety with a comforting embrace. Compassion and understanding were the only remedies available, temporary though they were.

To confirm that medicine is the best way for me to help others, I assisted a research team in the Emergency Room at University Medical Center (UMC). This experience brought me in direct contact with clinical care and provided me with the opportunity to witness and participate in the “behind-the-scenes” hospital operations. Specifically, we analyzed the therapeutic effects of two new drugs – Drug A and Drug B – in patients suffering from acute ischemic stroke. The purpose of this trial was to determine the efficacy and safety of these agents in improving functional outcome in patients who had sustained an acute cerebral infarction. My duties centered around the role of patient-physician liaison, determining patients’ eligibility, monitoring their conditions, and conducting patient histories.

I continued to advance my research experience at the VA Non-Human Primate Center. During the past year, I have been conducting independent research in endocrinology and biological aspects of anthropology. For this project, I am examining the correlation between captive vervet monkeys’ adrenal and androgen levels with age, gender, and various behavioral measures across different stress-level environments. I enjoy the discipline and responsibility which research requires, and I hope to incorporate it into my career.

Anthropology is the study of humans; medicine is the science and art of dealing with the maintenance of health and the prevention, alleviation, or cure of disease in humans. From my work at UMC and my observation of my father’s practice, I know medicine will allow me to pursue an art and science that is tremendously gratifying and contributes to the welfare of those around me. My anthropology classes have taught me to appreciate cross-cultural perspectives and their relationship to pathology and its etiology. Firsthand experience with exercise therapy and nutrition has taught me the invaluable role of prevention. Medical school will now provide me with the technical knowledge to alleviate a crise de foie."

[ Click here to view an excerpt from the original draft of this essay. ]

Lessons From Medical School Sample Essay #4: The Anthropology Student

With a diverse background that includes anthropology studies, work as a certified physical trainer, and experience in clinical medical research, this applicant builds a strong case for their logical and dedicated choice of a medical career.

• An engaging opening that frames the storyline This writer cleverly uses an example from anthropology class, linking the description of a heavy, gourmet French meal to an appreciation for cross-cultural understanding that will be an asset during their medical career. Notice that the writer is not describing their own personal experience here but piggybacked on a class lesson to create a colorful, engaging opening.
• A solid variety of relevant experiences In this six-paragraph essay, the writer links their lessons from anthropology studies to a firsthand understanding based on observing how their surgeon-father related to patients, to becoming a physical trainer directly helping others, and then to two different kinds of medical research. Each experience builds logically and chronologically on what came before, adding to the substance of the applicant’s preparation for medical school.
• A powerful personal experience with a client In the third paragraph, the writer’s experience working with a patient with lupus is particularly strong and memorable. Their initial success with Sharon is followed by an almost immediate and radical decline in her condition. This is a moving anecdote that shows the applicant’s understanding of the limitations of medicine – and the power of compassion.
• An excellent summary paragraph that ties everything together The final paragraph isn’t the place to offer new information, and this one doesn’t. Instead, it reminds the reader about the strong foundation the writer built from academics to career and medical research. Readers will be persuaded that after these experiences and reflections, the applicant truly appreciates “cross-cultural perspectives and their relationship to pathology and its etiology,” as well as the “firsthand experience with exercise therapy and nutrition teaching the invaluable role of prevention.”

Don’t Write Like This!

As the time approached for me to set my personal and professional goals, I made a conscientious decision to enter a field which would provide me with a sense of achievement and, at the same time, produce a positive impact on mankind. It became apparent to me that the practice of medicine would fulfill these objectives. In retrospect, my ever-growing commitment to medicine has been crystallizing for years. My intense interest in social issues, education, and athletics seems particularly appropriate to this field and has prepared me well for such a critical choice...

I’ve been asked many times why I wish to become a physician. Upon considerable reflection, the thought of possessing the ability to help others provides me with tremendous internal gratification and offers the feeling that my life’s efforts have been focused in a positive direction. Becoming a physician is the culmination of a lifelong dream, and I am prepared to dedicate myself, as I have in the past, to achieving this goal.

Lessons from Don’t Write Like This

This is an excerpt from the original draft of the Anthropology Student’s AMCAS essay. We are not including the whole thing because you can get the idea all too rapidly from just this brief portion. Note the abundant use of generalities that apply to the overwhelming majority of medical school applicants. Observe how the colorless platitudes and pomposity hide any personality. Can you imagine reading essays like this all day long? If so, then imagine your reaction to a good essay.

More sample essays

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Med school personal statement FAQs

1. when should i start writing my personal statement for medical school.

Typically, traditional applicants who have a goal of submitting their AMCAS or AACOMAS application in June write their personal statement after they take the MCAT in March. Starting the prewriting for the personal statement earlier than that is fine too; however, if an applicant plans to sit for the MCAT in the early spring, writing a compelling personal narrative while preparing for the MCAT can often be too much. Both require very different kinds of thinking. The intensity of studying for the MCAT, and the empirical thinking it requires, can interfere with the imaginative brainstorming needed to find your topic and develop it.  

Before focusing on the personal statement, look at all the elements of the primary application. As a whole, the personal statement, activities, MMEs, MCAT, transcript, biographical information and letters, will portray you. One element alone is not enough to bring out the whole you. It might help to strategize about how (and where) to highlight different elements of your background, experience, and character in the different parts of the primary application. Then work on the personal statement knowing what aspects of you are already represented in the other sections of the application. This way, each element adds value to the application and contributes to a more complete picture of you.

It makes sense to compartmentalize completing different parts of the application. Many applicants take the time they need to focus on one application component at a time, which seems to help them be thorough. 

Don’t underestimate how much time it takes to write well. Exploring ideas in writing, developing those ideas, showing rather than telling a story, staying clear, writing fluidly, surmising maturely and insightfully, takes much more time than most people anticipate. So, don’t wait until Memorial Day to write your essay and intend to submit on June 1. Give yourself the churn time writing well needs. Also, give yourself time to put a draft down for a day or two and return to it when you’re able to read it afresh. Sometimes, we revise over and over again in one sitting to the point that we can no longer hear the story or its sense because we have been rehearsing and revising a draft to beat the clock. Doing this is a risky way to go about the personal statement. Remember, this essay should be a very impressive part of your application, not merely one more part of the application to finish. At the end of the day, the medical school personal statement is a window that allows others to see you, know you as a person, know you better and beyond your achievements.

2. How do I find the perfect personal statement topic? Does one exist?

Certainly, some ideas are better than others, and one idea might work better for one person and not so well for someone else. However, there is no “perfect” topic. In fact, writing an essay with the approach of trying to out-psych this important application requirement is likely not the strongest way to find your best topic, nor is it the best way to engage your readers. 

Instead, consider the following approach. What is an experience you’ve had that matters greatly in helping others understand who you are as a future physician? Why medicine, not in general, but for you, demonstrated by way of a story about an experience that directly ties to being a physician or indirectly demonstrates your sound character as it corresponds with human qualities medical schools desire. When we read what kinds of people medical schools seek, it’s easy enough to identify quite a few character traits that appeal to many schools: compassion, resiliency, adaptability, selflessness, inclusivity, and altruism among them. What experience, when written with key details and description, reveals who you really are?

3. How do you choose the right amount of personal qualities to list?

A strong medical school personal statement should not replicate other parts of the application, with the exception of it being a specific story that stems from a particular experience associated with one of your activities. Otherwise, there’s no listing in this essay. Unfortunately, some applicants do treat the personal statement as an opportunity to list awards, accolades, and experiences, paragraph by paragraph. Meanwhile, medical school admissions officers can see these awards and experiences in the Experiences section of the application. Rarely, if ever, does this kind of writing bring out voice, vision and identity. Instead, tell a true story, revised with care and precision, that shines with voice, vision and identity.

4. Are there any topics I should avoid for my medical school personal statement?

Certainly, one idea might work better for one person and not so well for someone else. So, there’s a subjectivity in what to write and what not to write. Generally, however, there are some topics to avoid. Don’t write about a time you felt cheated, inconvenienced, frustrated or angry. Sometimes, secondary essay prompts will ask you about a struggle or a mistake, and for these answers, it’s best to show how you turned the situation around or keenly learned from it. Don’t get too caught in childhood. Many applicants do write about a time when they were not yet grown; however, don’t get swallowed by it. Write the scene and then stay in the present to demonstrate your maturity and worthwhile hindsight.

Remember -- no matter what the topic, tone matters. 

5. What kind of experience should I include in my personal statement?

6. can the experience i use on my med school personal statement be from outside of college.

Absolutely. It is relatively common for applicants to only portray themselves as students, and this can be a problem. Sometimes, when applicants write about themselves as excellent students the tone of such a personal statement can sound boastful or pleading. Neither quality is advantageous. 

Seeing oneself in any other light can result in a stronger “snapshot” of who you are, as long as the theme or topic of your personal statement still suits the intention of the application in the first place – demonstrating who you are as an appealing candidate for medical school. When we consider the writing task for the personal statement to be much more story-driven, readers go on a descriptive journey. What journey would you like to share?

7. Should I talk about challenges I’ve faced?

If other parts of your medical school application suggest a struggle – whether a lower MCAT score or a notable weak semester on a transcript – it might be advantageous to explain what happened and how you turned that situation around. Whether writing about a challenge in the personal statement or secondaries, the key is to demonstrate resilience. Applicants with physical or cognitive disabilities may choose to write about seeking assistance -- whether a doctor, therapist or a tutor -- and how learning alternative strategies helped them figure out how to attain higher academic achievement. 

Sometimes challenges are circumstantial. Sometimes families face financial hardship (did the family breadwinner become unemployed and therefore everyone else had to work more hours, including you?), emotional stress (due to an ongoing illness, Covid-19, or a divorce?) or trauma (a death of a loved one, a house fire, a veteran/sibling returning home with PTSD). Sometimes an applicant has been a caregiver for someone in the family. Sometimes an applicant has taken a leave from school because of someone else’s struggles, or the emotional fallout on the applicant from someone else’s struggle – the loss of a childhood friend, for instance. Self-care is reasonable. We might need to share a life moment in order to frame the context of a life struggle, showing it in the context of responsibility rather than recklessness or immaturity. Showing how you stepped up in a challenging time can show that you are accountable and caring, as long as the story is told to these ends, rather than suggesting resentment or self-pity. Again, neither of these tones is advantageous, nor is blame. 

Occasionally applicants have been challenged by a course or by a professor, a classmate or teammate and feel unduly subjected to bias. If there’s discrimination involved, that might be a story to tell. If there’s a personality clash, that might not be a good story to tell. 

Finally, as any story of challenge moves along, it’s important to demonstrate what you did, what you learned, how you adapted, or what you now value from having had this life experience that you did not understand before. 

Being a doctor is rife with challenges. In the end, your readers may come to understand how you are an insightful leader with great resilience or a compassionate, problem-solver.

8. How do I focus my personal statement to show that I want to go into medicine and not another field in healthcare?

Great question. On the one hand, it’s a good idea to demonstrate your compassion for others and empathy for people suffering from illness. On the other hand, these are favorable attributes for nearly all healthcare workers -- not only doctors -- but for physician assistants, nurses, respiratory therapists, social workers and psychologists too. Since most applicants have done some shadowing of physicians, it’s not unusual for these experiences to contain moments of learning about being a physician through shadowing or through work in a clinic. However, the more clinical the story, the better especially if you’re applying to osteopathic schools of medicine. If you’re applying to allopathic schools of medicine, it’s possible you have some interest in being a researcher, so telling a story about working in a physician’s lab might demonstrate your insights into the value of research in light of disease or patient care. If you already have an affinity for a specialty, telling how you came to know this could be the way to go.

9. Do I introduce my desired field of healthcare in my personal statement?

Maybe. If you’re very committed and have demonstrated a trend in your activities from general volunteer work (older listings) to more specialized experience in a field of medicine (more recent listings), it may be a good idea to write up how you came to know one field of medicine was really your passion. 

Bear in mind that announcing a deep interest in a particular field of medicine may make you “a good fit” or “not a good fit” for some schools. So, if you do write up a story about your desired field of medicine for your personal statement, be sure your list of schools corresponds with this. For instance, if you want to be an obstetrician and you convey this in your personal statement, be certain your schools have clinical exposure or better yet offer specializations in obstetrics, or a required rotation through a hospital for women, for instance.

Lastly, by no means must you announce a desired field of healthcare in your personal statement. You may be asked about your specialized interests in medicine in a secondary or in an interview, so it’s a good idea to think this through, but no, you don’t have to tackle this in the personal statement.

10. What should my character limit be? 

The AMCAS and AACOMAS character limit for the personal statement is 5,300 characters with spaces. The TMDSAS character limit for the personal statement is 5,000 characters with spaces. It’s a good idea to use most if not all of this space for your personal statement. Also, try to avoid the temptation to use the same personal statement for AMCAS and AACOMAS. The osteopathic schools seek applicants who know and prefer an osteopathic orientation to medicine, so the AACOMAS personal statement should demonstrate your fit with osteopathic medicine, based on what story you choose to tell and how you tell it, or at the very least, in the conclusion.

11. How do I know when I’m ready to submit my med school personal statement?

I highly recommend getting feedback about this from a strong mentor, advisor or consultant. Accepted offers comprehensive consultation for every part of the writing process, from brainstorming, to outlining, to mentoring on ideas, and editing until a client has a solid final draft in hand, ready for submission. You can review these services here: Initial Essay Package

Generally speaking, when you’ve accomplished FAQ #2 and #3, avoided the pitfalls in #4, revised for clarity and quality of ideas, developed ideas engagingly, and meticulously revised for quality of writing, then, you may be done.

12. What if I don’t have enough space to discuss everything?

Then your topic is too large or unfocused, in which case you need to focus and narrow the scope of your essays. Or you have a bit of editing to do to eliminate wordiness, digressions, or overstatement Ultimately, you want your essay to be focused, clear, and engaging.

13. Should I personalize my personal statement to the med school I am applying to?

Only if you’re applying to one medical school. Otherwise, your personal statement will reach all schools listed in your AMCAS application or AACOMAS application. It is okay, however, to speak toward the ideals of your first choice, aspirational schools on your list. Other times, applicants choose to write toward the schools that are their safest bets. 

Your secondary/supplemental essays will give you plenty of opportunity to show you belong at an individual school.

14.  Can I talk about mental or physical health in my statement?

15. should i address any bad grades that i got in school.

Generally yes, as long as bad grades are truly bad grades. It’s likely that you do not need to address a rogue grade of B on a transcript. If you had a bad semester or two, the question becomes how and where to address them. The answer is an individual one dependent on the context. The one certainty: You definitely don’t want your entire application to be a rationalization of those bad grades. 

See FAQ #7. 

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• Medicine: How to Apply

Medicine: Anatomy of a Personal Statement

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Below is a personal statement from a recent applicant for A100 Medicine at Oxford. It is not perfect and it may not be suited to every medical school. There is no single template for success in terms of an application to Oxford. Other styles can be equally effective: we encourage individuality and diversity in our students. This statement is however a good example for an Oxford application because it helps us see that the applicant is attempting to match our selection criteria .

An applicant's personal statement is likely to be discussed by tutors during interview.

A well-written statement will not in isolation gain you an interview or a place. It forms one part of an application from a gifted applicant that can be considered alongside other information - academic record, BMAT score, school reference, interview performance - in the selection process at Oxford.

Statement & comments

Choosing to study medicine is not a decision I have taken lightly. It isn't a career I have wanted to do since a particularly young age, nor did a life changing event prompt my choice. I have thought very long and hard before deciding to apply.

At first glance, this might seem like a down-beat opening paragraph. Although you may think that an arresting opening statement will impress, admissions tutors may be sceptical of exaggerated descriptions of a revelatory moment or lifelong desire to become a doctor. This introduction shows honesty and a degree of introspection. Throughout the statement, the applicant works hard to show that they have a realistic view of medicine. You won't prove that you have the motivation for medicine by simply saying that you do: it is what you have done to inform yourself about the career - and the views that you have formed - that will convince us that you really know what being a doctor is like and that this is what you want to do.

Various periods of work experience have taught me much about the career. A local hospital placement gave me the opportunity to visit A&E, Radiology and Obstetrics and Gynaecology.

You won't prove that you have the motivation for medicine by simply saying that you do.

Whilst fleeting, these visits to the departments highlighted the variety and diversity of the fascinating specialities medicine encompasses. A placement shadowing a clinic staff was hugely informative regarding daily life as a doctor. During the day I sat in on consultations ranging from routine post natal checkups to discussions of treatment for young people with diabetes and overactive thyroid glands.

This student describes their experiences of healthcare that have helped them decide that they want to study and practise medicine. We understand that opportunities to obtain experience vary, so you won't be judged on what you've done: we want to know what you learned from doing it. The description of the placements here isn't over-exaggerated, and the applicant takes care to explain what they have seen and done and the insight each opportunity afforded them. The relatively detailed account of the infant's check-up conveys the impression of engagement during the placement and suggests an intellectual curiosity to understand the infant's condition and its treatment. The applicant also takes care to point out an example of the importance of good communication skills and argues how their sales position has helped them develop such skills.

Throughout my time there the doctor's genuine interest in his cases and unfaltering motivation highlighted to me the privilege of having such a stimulating profession. This, together with the ever advancing nature of a career in medicine, was brought to the fore by an infant who was having a check up as a result of her being put on an ECMO machine after her birth with Meconium Aspiration Syndrome. The ease with which the doctor broached and dealt with sensitive subject matter also emphasised the importance of a warm, approachable manner and an ability to communicate to a person on their level of understanding. I believe I have honed these skills and gained invaluable experience of the eccentricities of the general public myself in my job as a salesperson.

It is important to convey an impression of engagement and intellectual curiosity when talking about any work experience/placement/voluntary work.

Since February of this year I have volunteered in a care home for a couple of hours each week. I assist with serving meals to the residents as well as feeding one of the more infirm ladies. My time there has brought to my attention the more unpleasant side of medicine and has proved by far the most useful work experience I have had; preparing me for the stark realities of physical ageing and senility. In spite of this, I genuinely enjoy my time there; giving residents, some of whom go months without visitors, 10 minutes of my time to chat can be very rewarding in the obvious enjoyment they get from it. The experience has shown me very clearly the importance of caring for the emotional as well as the physical needs of patients.

This paragraph reaffirms the applicant's motivation for medicine. They admit that working in a nursing home is not glamorous but explain how rewarding it has been. There is evidence of analytical skills here and there is no doubt that the applicant has become well-informed about the realities of healthcare. Empathy comes across as well, with the applicant recognising that a brief interaction can have such a positive effect on the overlooked residents of the home.

Outside of my lessons I enjoy orienteering with a local club. As part of an expedition I took part in, we walked 80km over 4 days in torrential rain. The challenging conditions demanded teamwork and trust to maintain morale and perform effectively as a group; as well as calm rational thought in stressful situations. Also, through this activity and the people I met, I have become a member of the SJA which has enabled me to gain first aid qualifications and go out on duties.

Although the bulk of a personal statement should be academic-related, it is important to show a life outside of studying. The involvement in a club or association demonstrates wider spare time interests, and the description of the challenging walking expedition provides evidence that the student can work with others and can cope in an arduous situation, obliquely suggesting that they might have the capacity for sustained and intense work . The student also shows that they understand that taking time out to relax and manage any stress is important, and conveys the impression of good time management. The passing reference to the drama group reinforces the impression that this applicant is a team-player. It is useful to describe sporting or musical interests although, as, this applicant shows, these non-academic interests don't need to be particularly high-powered ones.

Other activities I enjoy include drama - I was a member of a local group for 6 years - cycling and playing the guitar and piano which allow me to relax.

Non-academic interests don't need to be particularly high-powered.

I know that medicine is not a "9 to 5" job and is by no means the glamorous source of easy money it is often perceived to be. I understand the hours are long and potentially antisocial and that the career can be physically exhausting and emotionally draining. It is apparent that becoming a medic will involve inherent sacrifice.

However medicine is also a deeply gratifying and fascinating career path. I want to be a medic because my passion and aptitude is foremost scientific and to me 5 or 6 years more of formal education followed by a lifetime of further learning sounds like a stimulating career option and, thankfully, a far cry from the monotony some jobs pose. Nevertheless, as an intrinsically social person, I would relish a career requiring the development of strong empathic relationships with patients too. Crucially, I know I have the enthusiasm, capacity for hard work and the open and enquiring mind needed to succeed in such a fulfilling vocation.

In the concluding paragraphs, the statement is emphasising that, although aware of the negative aspects associated with the practice of medicine, fact-finding placements have given the applicant the insight and motivation to be certain that it is the right career for them. The applicant ends by summarising the key personal attributes that they believe make them well-suited to medicine.

Verdict and advice for improvement

Of course, there is room for improvement with this statement. No reference is made to the scientific subjects that are being studied at school or to particular modules that the applicant has found particularly exciting: this could have helped convey enthusiasm and curiosity in science. Although the applicant asserts that they have an 'open and enquiring mind', there is no description of any extracurricular project or reading that the applicant might have undertaken, perhaps to help them understand a highly-charged ethical issue.

Despite those omissions, this is an effective personal statement. It is well constructed, connects with the reader, and the material flows in a logical sequence. It further conveys the impression that the applicant has done the research and knows exactly what is in store: they are not applying with a naive view or because that is what is expected of them. Writing a statement along these lines would provide a good foundation for a competitive applicant and offers lots of material that can be discussed at an interview.

• Course Structure
• Academic Entry & Age Requirements
• Selection Criteria
• Health & Fitness to Practise
• Application Checklist
• Application Process
• Introductory Reading
• Writing your Personal Statement
• Anatomy of a Personal Statement
• Graduate Applicants
• Mature Applicants
• International Applicants
• Mitigating circumstances
• Shortlisting Process and Admissions Statistics
• Fees and Funding

Medical School Personal Statement Hooks (13 Examples)

Medical school personal statement hooks, although they need to be used very carefully, can certainly help bring some personality and originality to an application.

Making up the introductory paragraph of your essay that leads the reader in, they’re also very important.

But it can be hard knowing where to start when it comes to putting them together. Or understanding what works best and why.

To help, I’ve decided to put together 13 hook examples in this article.

Adding my own small critique (on what I think does or doesn’t work), maybe they can offer some guidance when it comes to deciding what to use for your own hooks.

Along with examples, here’s what else we’ll cover to help you with your hooks:

• Hook topic ideas
• What makes a good/bad hook
• Tips on how to write an effective personal statement hook

Ready to get started? Let’s go.

What is a Hook?

A hook is the opening of an essay or a general theme or topic underpinning it.

It’s important because it’s the first thing the reader will see. Therefore it provides the best opportunity for engagement.

Depending on what your prompt is, the hooks you choose can differ across applications. It’ll need to fit a small percentage of the overall word count too (usually around 5,300 characters).

Related : Medical School Diversity Essay Prompts (21 Examples)

A hook can also start from anywhere. It can be a conclusion. Or an insight.

Many applicants choose to present it as a descriptive story rather than a simple “I” statement.

As you’ll see from the following examples!

13 Medical School Personal Statement Hook Examples

To really see and understand these hooks in action, it’s important you click through to those you like and read the examples in their broader context.

The ones picked out here (except those from Reddit) are the hooks included in the general introductions of larger essays.

Examples #1 and #2: General Vs Personal Hooks

“Hope to see you again next week,” I said, while handing the drug addict a packet of syringes. u/throwawatyyyy

Ma’am is this your son?” It was a question I always got as a kid, adopted into a biracial family that was not my own. u/boopboopthesnoot

These examples, taken from Reddit, show some insight into the value of hooks.

The first one received feedback for being a little too generic (overly focused on the “I want to be a doctor because I want to help people” trope) and clunky (using the words “drug addict”).

While the second is more successful; being more personal.

Examples #3 and #4: Engaging Hooks

My story begins at the age of six. I am dressed in a tiny suit with a miniature cello, the perfect size for a doll. It is the debut of The Aloha Trio: I am on cello, and my two older sisters are on violin and flute. My mother describes it as a way of sharing our Hawaiian spirit of “aloha” with a deserving audience. I think of it as torture.

My first patient was a man in his 60’s who fell down a few stairs at the hockey complex. His foot slipped out from under him while climbing the concrete steps, and he smashed his knee and elbow in the process. As a newly certified EMT, it was the first time I was responsible for another’s health. – U.S. News

The two examples here, held up as successful by the respective adcoms reviewing them, are commended for “capturing the reader’s imagination” and showing “clear motivation” as to why they want to become a doctor.

You’ll see the second example is much more measured and matter-of-fact in tone.

Admissions teams aren’t expecting masterful writing verging on “Creative Writing 101”.

Considered and well-thought-out hooks that engage without turning off are far more appropriate!

Examples #5 and #6: Poignant Vs Comedic Hooks

“I love Scriabin!” exclaimed Logan, a 19-year-old patient at the hospital, as we found a common interest in the obscure Russian composer. I knew Logan’s story because it was so similar to my own: a classically-trained pianist, he was ready to head off to college in a month, just as I had the year before. Yet it was Logan who was heading into surgery to remove a recently-discovered brain tumor.

At the beginning of the first Alternative Spring Break (ASB) meeting that I was leading in front of a group of nervous volunteers, I used an icebreaker, Two Truths and a Lie. Being a common face at my campus’s student activities, I have played this game perhaps one too many times. Unlike everyone else who had to take time to think about their interesting truths, I would say the same thing every time. “I want to be a pediatrician, I have alpacas, and I have llamas.” I do not have llamas. – Med School Insiders

Med School Insiders hold up the first example here as better than the second (based on the greater context).

Both hooks are strong. The second one, which uses an anecdote to draw the reader in, makes effective use of humor.

Be careful that your hook helps “show” rather than “tell” your suitability for medicine.

Examples #7 and #8: Narrative Vs Direct Hooks

I made my way to Hillary’s house after hearing about her alcoholic father’s incarceration. Seeing her tearfulness and at a loss for words, I took her hand and held it, hoping to make things more bearable. She squeezed back gently in reply, “thank you.” My silent gesture seemed to confer a soundless message of comfort, encouragement and support.

I was one of those kids who always wanted to be doctor. I didn’t understand the responsibilities and heartbreaks, the difficult decisions, and the years of study and training that go with the title, but I did understand that the person in the white coat stood for knowledge, professionalism, and compassion.  – BeMo

Example #7’s hook here seems to be a lot more impactful than #8’s.

The first is more personal and unique, the second a little too generic and expected.

Example #9: Inquisitive Hooks

Jeremy sobbed quietly, taking deep, shuddering breaths. He wiped his eyes on his favorite Spiderman T-shirt, the one he had been wearing hours earlier when he’d heard the news: His mother had been arrested again, and he may not see her for a very long time. What do you say to a ten-year-old child in that situation? – Transizion

This hook is a great example of capturing the reader and leaving them wanting more.

The use of the question forces the reader to be active in the story.

Your hook should always consider the reader.

Asking questions of them can be a useful way to achieve this.

Example #10: Authentic Hooks

New Orleans was hot and humid during the summer months of 2014–no surprise there. However, for a native Oregonian like me, waking up to 90-degree and 85%-humidity days initially seemed like too much to bear. That was until I reflected on the fact that my temporary discomfort was minute in contrast to the destruction of communities and emotional pounding experienced by the people of New Orleans during and after Hurricane Katrina nine years earlier. – Shemassian Consulting

This example hook has authenticity at its core, providing a tangible example of how the subject helped better the situation.

The individual doesn’t have to tell the reader they are compassionate, it’s shown by the events included in the hook itself.

As Shemassian suggests; your essay doesn’t need to have any “a-ha moment” or a sudden realization.

A slow unfurling story coupled with a descriptive, relatable hook, is often more realistic and grounded in the eyes of the reader.

Example #11 and #12: Contrarian Vs “Off-Topic” Hooks

Mary was well known at our clinic by all of our doctors, nurses, and medical staff. Based on her sharp intellect and cheerful pattern of making all of our staff feel like we were her best friends, it would be difficult to tell why she frequently visited the hospital. Outside of her use of a walker, her Parkinson’s disease diagnosis had not slowed her down much…I wanted to give her the best care possible, whether through asking our great nurses to check in on her or offering an extra blanket or favorite snack to ensure comfort throughout her stay. However, I was simultaneously frustrated that my ability to help Mary ended there. This lingering lack of fulfillment has served as a great motivator to find more ways to do more for patients like her.

My palms had never been as sweaty as when I walked on stage with my trombone in front of a 500-plus member audience on June 9 th , 2015. Sure, I was pretty good, but I would like to think that being invited to play Curtis Fuller’s  Along Came Betty  at the Omaha Black Music Hall of Fame had as much to do with the music skills I had honed over the past decade as it did with training the 8-member band of 10 to 13 year-olds from the inner city to join me on that same stage. I was nervous because this performance was for them; I needed to be at my best. – Prospective Doctor

The first hook here shows good use of contrast.

The subject is at odds with their desire to help the patient but also held back from doing so. Hooks that express contrary viewpoints like this are often very impactful.

Hook #12 is great because it’s so different. We take a break from the common themes of medicine and are transported into another world (but still one with transferrable skills and experiences), which also leads us to want to find out more (did the performance go well?)

Depending on the prompt, your hook can go down unique avenues like this.

It doesn’t always need to start with direct relevance to medicine.

Example #13

The AIDS hospice reeked from disease and neglect. On my first day there, after an hour of “training,” I met Paul, a tall, emaciated, forty-year-old AIDS victim who was recovering from a stroke that had severely affected his speech. I took him to General Hospital for a long-overdue appointment. It had been weeks since he had been outside…While elated that I had literally made Paul’s day, the neglect and emotional isolation from which he suffered disgusted me. This was a harsh side of medicine I had not seen before. Right then and there, I wondered, “Do I really want to go into medicine?” – Accepted.com

Again, this hook is an example of making a contrary point while “showing” the applicant’s relevant extracurricular experience.

In a pile of 20-30 essays, I bet this hook stands out.

Questioning if you even want to go into medicine in the introduction of a med school application is a risk. But it’s also a risk that, if expertly answered, could have a fantastic payoff.

If you’re confident you can back it up with the rest of your essay, risky hooks like this can work well.

Medical School Personal Statement Hook Topics

Coming up with ideas on what to use for your essay hook can be just as difficult as actually writing it.

Here are some popular ideas used by previous applicants that could serve as inspiration:

• Being first in your family to go to college
• Losing a loved one to suicide
• Raising a family
• Graduating early
• Growing up in poverty/experiencing homelessness
• Overcoming physical disability
• Working construction
• Military career
• Teaching career
• Polyglot/speaking multiple languages
• Running political campaigns
• Martial arts instructor
• Raising goats/chickens
• Competitive eSports athlete
• Professional musician
• Powerlifting and sports training

You can turn almost anything personal to you into a hook.

Spend some time thinking about the things you’ve done/achieved/overcome in life and make a list first (before you start writing).

The important thing is that your personal statement answers some form of the question; “ why medicine ?”

Your hook ultimately should lead into that.

Related : “ Why Do You Want To Be A Doctor?” (Reddit’s 19 Best Answers!)

Related Questions

Do personal statements need a hook.

Hooks aren’t always appropriate for personal statements. There’s no cut-and-dry rule that says you have to start with them.

For many applications, however, hooks can be very useful. Especially if you consider the admissions committee member reading through 20-40 similar-sounding essays in a single day.

In those cases, a good hook can help you grab the attention of the reader and stand out. As well as sell other aspects of yourself that aren’t always obvious or evident in your application.

Whether that actually betters your chance of getting into med school, is probably too much of a stretch to say. But it definitely could help differentiate you.

What is a good hook for a personal statement?

The best hooks are ones that are appropriate to an activity you’re introducing. The more unique they are, and the more effective at fuelling curiosity and encouraging someone to keep reading, the better.

“I’m sick and don’t know if I’ll get better.” Hearing those words is probably the most painful memory I have about my mother. And I’m reminded of it often when I talk with family at the Memorial Hospital Cancer Center.

But there is a fine line between being overly theatric and measured.

A good hook usually does one (or more) of the following:

• Avoids the cliche “I love science and helping people” opener
• Shows doesn’t tell
• Humanizes the subject
• Personal to you (doesn’t read as if it could have been written by anyone else)
• Carefully balances unique and shocking (it still needs to be an effective, serviceable essay)
• Avoids clunky langage/being tonally offensive

A good way to find out if you have a strong hook is to have it critiqued by an editor.

The examples above are just that (examples).

Without knowing the other aspects of a student’s application (or story), their value can be hard to judge!

That’s why it’s also important that the hook you use ties into both the body of your essay and its final paragraph.

What is a bad hook?

A bad hook is usually contrived. It might feature a run-of-the-mill quote or smack of unoriginality. Or tries to define something rather obvious.

An example of a bad hook could be something like:

The definition of medicine has gone through as many changes as the human race. Straddling the worlds of both art and science, it continues to remain unconfined to the boundaries of language.

This is both general (lacks any sense of personality) and empty.

Bad hooks for personal statements miss emotive marks and say little about the person writing them.

Or they over-dramatize the mundane, possibly differentiating you in a negative way.

Why are personal statement hooks so hard to write?

The big reason why hooks are so difficult to write is because of the pressure. They are the opening lines of a statement that’s meant to distill your entire ethos and philosophy for studying medicine into a few short paragraphs. And also summarize countless hours of extracurricular prep and everything else.

But another key reason is that you’re simply not used to crafting them.

Because of that, supposed “good” hooks can sometimes look cliched and cringe-inducing.

Your general lack of experience makes it hard to tell good ones from the bad.

How do you write a personal statement hook for medical school?

Now we’ve explored the example hooks and spent some time in discussion over what could make them good/bad, here are some general tips on how to go about writing them:

• Start by listing down all the possible ideas you could use for hooks (use the topic ideas to help)
• Choose the top 3-5 ideas and start turning them into short introductory paragraphs (use the examples as models)
• Get feedback by running them past other applicants/successful med students
• Go with the hook that you feel best suits the potential body of the essay

Starting with hooks is probably the best way to begin framing your essay as a whole.

Just getting in the practice of coming up with several ideas is great for overcoming any resistance to writing and helping you gain the confidence in believing you can create something great.

As a quick reminder, here are some of the top do’s/don’ts to keep in mind as you move through this process

• Do match the hook to the prompt (don’t make it seem random or off-topic)
• Don’t feel that the hook has to be the starting sentence only (it can be 2-3 sentences or an entire opening paragraph)
• Do “show”, don’t “tell”
• Do road test your hooks with friends/family
• Don’t include controversial topics
• Don’t be overly flowery (it’s a pointed essay, not a meandering novel)
• Don’t make it a sob story
• Don’t include patient names
• Don’t be repetitive
• Don’t include anything you wouldn’t want to talk about in an interview
• Don’t speak negatively (of yourself or others)
• Don’t use medical jargon
• Don’t use acronyms without writing them out first

Ready to start coming up with some hooks?

Born and raised in the UK, Will went into medicine late (31) after a career in journalism. He’s into football (soccer), learned Spanish after 5 years in Spain, and has had his work published all over the web. Read more .

2 Med School Essays That Admissions Officers Loved

Here are tips on writing a medical school personal statement and examples of essays that stood out.

2 Great Med School Personal Statements

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A compelling medical school admissions essay can address nearly any topic the applicant is interested in, as long as it conveys the applicant's personality.

A personal statement is often a pivotal factor in medical school admissions decisions.

"The essay really can cause me to look more deeply at the entire application," Dr. Stephen Nicholas, former senior associate dean of admissions with the Columbia University Vagelos College of Physicians and Surgeons , told U.S. News in 2017. "So I do think it's pretty important."

A compelling medical school admissions essay can address nearly any topic the applicant is interested in, as long as it conveys the applicant's personality, according to Dr. Barbara Kazmierczak, director of the M.D.-Ph.D. Program and a professor of medicine and microbial pathogenesis with the Yale School of Medicine.

“The passion that the writer is bringing to this topic tells us about the individual rather than the topic that they’re describing, and the essay is the place for us to learn about the applicant – who they are and what experiences have brought them to this point of applying to medical school,” she told U.S. News in 2017.

Rachel Rudeen, former admissions coordinator for the University of Minnesota Medical School , says personal statements help medical schools determine whether applicants have the character necessary to excel as a doctor. "Grit is something we really look for," she says.

Evidence of humility and empathy , Rudeen adds, are also pluses.

Why Medical Schools Care About Personal Statements

The purpose of a personal statement is to report the events that inspired and prepared a premed to apply to medical school, admissions experts say. This personal essay helps admissions officers figure out whether a premed is ready for med school, and it also clarifies whether a premed has a compelling rationale for attending med school, these experts explain.

When written well, a medical school personal statement conveys a student's commitment to medicine and injects humanity into an admissions process that might otherwise feel cold and impersonal, according to admissions experts.

Glen Fogerty, associate dean of admissions and recruitment with the medical school at the University of Arizona—Phoenix , put it this way in an email: "To me, the strongest personal statements are the ones that share a personal connection. One where a candidate shares a specific moment, the spark that ignited their passion to become a physician or reaffirmed why they chose medicine as a career."

Dr. Viveta Lobo, an emergency medicine physician with the Stanford University School of Medicine in California who often mentors premeds, says the key thing to know about a personal statement is that it must indeed be personal, so it needs to reveal something meaningful. The essay should not be a dry piece of writing; it should make the reader feel for the author, says Lobo, director of academic conferences and continuing medical education with the emergency medicine department at Stanford.

A great personal statement has an emotional impact and "will 'do' something, not just 'say' something," Lobo wrote in an email. Admissions officers "read hundreds of essays – so before you begin, think of how yours will stand out, be unique and different," Lobo suggests.

How to Write a Personal Statement for Medical School

Lobo notes that an outstanding personal statement typically includes all of the following ingredients:

• An intriguing introduction that gets admissions officers' attention.
• Anecdotes that illustrate what kind of person the applicant is.
• Reflections about the meaning and impact of various life experiences .
• A convincing narrative about why medical school is the logical next step.
• A satisfying and optimistic conclusion.

"You should sound excited, and that passion should come through in your writing," Lobo explains.

A personal statement should tie together an applicant's past, present and future by explaining how previous experiences have led to this point and outlining long-term plans to contribute to the medical profession, Lobo said during a phone interview. Medical school admissions officers want to understand not only where an applicant has been but also the direction he or she is going, Lobo added.

When premeds articulate a vision of how they might assist others and improve society through the practice of medicine, it suggests that they aren't self-serving or simply interested in the field because of its prestige, Lobo says. It's ideal when premeds can eloquently describe a noble mission, she explains.

Elisabeth Fassas, author of "Making Pre-Med Count: Everything I Wish I'd Known Before Applying (Successfully) to Medical School," says premeds should think about the doctors they admire and reflect on why they admire them. Fassas, a first-year medical student at the University of Maryland , suggests pondering the following questions:

• "Why can you really only see yourself being a physician?"
• "What is it about being a doctor that has turned you on to this field?"
• "What kind of doctor do you imagine yourself being?"
• "Who do you want to be for your patients?"
• "What are you going to do specifically for your patients that only you can do?"

Fassas notes that many of the possible essay topics a med school hopeful can choose are subjects that other premeds can also discuss, such as a love of science. However, aspiring doctors can make their personal statements unique by articulating the lessons they learned from their life experiences, she suggests.

Prospective medical students need to clarify why medicine is a more suitable calling for them than other caring professions, health care fields and science careers, Fassas notes. They should demonstrate awareness of the challenges inherent in medicine and explain why they want to become doctors despite those difficulties, she says.

Tips on Crafting an Excellent Medical School Personal Statement

The first step toward creating an outstanding personal statement, Fassas says, is to create a list of significant memories. Premeds should think about which moments in their lives mattered the most and then identify the two or three stories that are definitely worth sharing.

Dr. Demicha Rankin, associate dean for admissions at the Ohio State University College of Medicine , notes that a personal statement should offer a compelling portrait of a person and should not be "a regurgitation of their CV."

The most outstanding personal statements are the ones that present a multifaceted perspective of the applicant by presenting various aspects of his or her identity, says Rankin, an associate professor of anesthesiology.

For example, a premed who was a swimmer might explain how the discipline necessary for swimming is analogous to the work ethic required to become a physician, Rankin says. Likewise, a pianist or another type of musician applying to medical school could convey how the listening skills and instrument-tuning techniques cultivated in music could be applicable in medicine, she adds.

Rankin notes that it's apparent when a premed has taken a meticulous approach to his or her personal statement to ensure that it flows nicely, and she says a fine essay is akin to a "well-woven fabric." One sign that a personal statement has been polished is when a theme that was explored at the beginning of the essay is also mentioned at the end, Rankin says, explaining that symmetry between an essay's introduction and conclusion makes the essay seem complete.

Rankin notes that the author of an essay might not see flaws in his or her writing that are obvious to others, so it's important for premeds to show their personal statement to trusted advisers and get honest feedback. That's one reason it's important to begin the writing process early enough to give yourself sufficient time to organize your thoughts, Rankin says, adding that a minimum of four weeks is typically necessary.

Mistakes to Avoid in a Medical School Personal Statement

One thing premeds should never do in an admissions essay is beg, experts say. Rankin says requests of any type – including a plea for an admissions interview – do not belong in a personal statement. Another pitfall to avoid, Rankin says, is ranting about controversial political subjects such as the death penalty or abortion.

If premeds fail to closely proofread their personal statement, the essay could end up being submitted with careless errors such as misspellings and grammar mistakes that could easily have been fixed, according to experts. Crafting a compelling personal statement typically necessitates multiple revisions, so premeds who skimp on revising might wind up with sloppy essays, some experts say.

However, when fine-tuning their personal statements, premeds should not automatically change their essays based on what others say, Fogerty warns.

"A common mistake on personal statements is having too many people review your statement, they make recommendations, you accept all of the changes and then – in the end – the statement is no longer your voice," Fogerty wrote in an email. It's essential that a personal statement sound like the applicant and represent who he or she is as a person, Fogerty says.

Dr. Nicholas Jones, a Georgia-based plastic and reconstructive surgeon, says the worst error that someone can make in the personal statement is to be inauthentic or deceptive.

"Do not lie. Do not fabricate," he warns.

Jones adds that premeds should not include a story in their personal statement that they are not comfortable discussing in-depth during a med school admissions interview . "If it's something too personal or you're very emotional and you don't want to talk about that, then don't put it in a statement."

Medical School Personal Statement Examples

Here are two medical school admissions essays that made a strong, positive impression on admissions officers. The first is from Columbia and the second is from the University of Minnesota. These personal statements are annotated with comments from admissions officers explaining what made these essays stand out.

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Guides & Info

Medicine Personal Statement Examples

Last updated: 29/6/2023

• Is Medicine Right for Me?
• What do Doctors do?
• The Daily Life of a Doctor
• How to apply to medical school
• Different Routes into Medicine
• Factors to Consider
• Medicine at Oxford and Cambridge
• Your Fifth UCAS Choice
• Getting Your Grades
• Extra-curricular Activities
• What is the UCAT?
• Preparing for Your UCAT Test Day
• After Your UCAT
• BioMedical Admissions Test (BMAT)
• Work Experience and Dental Schools
• NHS Work Experience
• Personal Statement
• Medicine PS Examples
• Dentistry PS Examples
• UCAS References
• Medical and Dental School Interviews
• Multiple Mini Interviews (MMIs)
• Medical School Interview Questions
• Dental School Interview Questions
• Graduate Entry Courses
• Foundation and Access Courses
• International students
• Taking a Gap Year
• Medicine in Australia and NZ
• Medicine in Ireland Medicine in Eastern Europe
• Other Roles in Healthcare
• What Our "Plan B" Looked Like

Your UCAS personal statement is a chance to showcase the skills, attributes, and experiences which make you suited to studying medicine. This can be quite a daunting prospect, especially when you have to boil all that down to just 4,000 characters, or 47 lines. 

In this article, we will:

• Examine examples of strong and weak medicine personal statements (interested in dentistry? Check out dentistry personal statement examples )
• Help you learn what you should and shouldn't include in your medicine personal statement

Want to explore more examples? Our Personal Statement Course has over 100 personal statement examples to help you find your voice.

What you'll find in this article:

Personal statement example 1 – introduction

Personal statement example 2 – introduction, personal statement example 1 – main body, personal statement example 2 – main body, personal statement example 1 – conclusion, personal statement example 2 – conclusion, strong personal statement example, weak personal statement example, what should your personal statement include.

To get into medical school , your personal statement should:

• Demonstrate meaningful insight into the profession, in the form of work experience or independent research. This could be partly based on medical books or podcasts when medical work experience is not possible
• Reflect on your strengths, weaknesses, and experiences
• Mention your extracurricular activities
• Discuss your academic interests and achievements

'At the moment I am working towards A-Level Chemistry, Biology and Maths. I achieved my AS-Level in Spanish but decided to drop it to focus on my more medically relevant subjects. I’ve been dreaming of studying medicine since I was a young child, and this was only reinforced when I contracted measles during my primary school exams. This affected my performance, but I found that this motivated me rather than discouraged me. A particularly inspiring doctor was heavily involved in helping me deal with the pressure. I was inspired by her to become a doctor myself and help others in a similar way. I am particularly interested in science and as such the practical side of medicine interested me. I’ve always enjoyed chemistry and biology the most, and have best learned when trying to link the pure science I learn in school back to it's practical and useful real-world applications. This is what is particularly interesting about medicine to me - you can apply pure, evidence-based science in a clinical and practical setting to have an obvious positive effect. Inspired by this interest, I invested in a subscription to the New Scientist magazine. I’ve read about a huge number of fascinating discoveries and how they’ve been applied in medical settings.'

This introductory section has some promising features, but there are areas the author could improve:

• The introductory sentence doesn’t catch the reader’s attention or hold much relevance for a medical personal statement. This sentence would be better suited to a subsequent section on the author’s academic achievements, and it would need to be supplemented with a suitable explanation as to why the chosen subjects are relevant for medicine. 
• The author uses an anecdote to illustrate why they first developed an interest in medicine. This is a good idea, but the anecdote they've chosen is not the most suitable. It references ‘primary school exams’, which uses the cliché of wanting to do medicine from a young age. This is not only overused, but is also underdeveloped. 
• The applicant mentions feeling under pressure for these primary school exams. This won’t fill the reader with confidence that the author will be able to cope with the demands of medical school and a career as a doctor. 
• The introduction should open with the anecdote rather than academic achievements. A strong and memorable opening line will catch the admission tutor’s attention, and gives the student an opportunity to summarise why they want to study medicine.
• It is far too long. A good introduction should be around 4-6 lines.

There are some parts of the introduction that are more effective:

• The part discussing why they enjoy chemistry and biology is useful – it links their love for pure science back to the passion they mentioned earlier for helping people. This demonstrates the blend of empathy and interest in science that medical schools will be looking for. 
• The same part also introduces the candidate’s reading of medical literature, which they could choose to discuss in more depth later in the statement, or which might be something that interviewers could choose to examine in more detail.

'From a young age, my real fascination in life has been science - in particular, the incredible intricacy of the human body. My passion to discover more about its inner workings fuelled my motivation to study medicine, and the challenging yet rewarding nature of the job leaves me certain that I want to pursue it as a career. I think that my chosen A-Levels have only made me more determined to become a doctor, while simultaneously allowing me to develop and improve my skills. I have become a better problem-solver by studying physics and maths, while also learning the importance of accuracy and attention to detail. I’ve particularly enjoyed chemistry, which has again helped me improve my problem solving skills and my ability to think rationally and logically. Throughout my chemistry and biology A-Levels, I’ve been required to engage in practical work which has taught me how to design and construct an experiment. I’ve also become better at communicating with other members of my team, something I witnessed the importance of during my work experience in A&E. During recent months, I’ve started reading more medical publications such as the Lancet and the British Medical Journal. I’ve been particularly interested in how this evidence-based science can be applied to clinical practice to really make an impact on patients.'

This introduction contains some useful reflection and demonstrates some insight, but is quite jumbled. The main areas of weakness are as follows:

• The content is good but much of it would be better suited to a later section and should be explored in more detail while being linked back to medicine (for example, the whole second half could be included in a longer segment on academia). 
• The applicant mentions that they improved their problem-solving skills. How did they do this? Why is this important in medicine? 
• They say that medicine is demanding but that this attracts them to the job. What experiences have they had to show the demanding nature of it? Why does this attract them to it? 
• The author also briefly mentions a stint of work experience in A&E, but the rushed nature of the introduction means that they can’t go into detail about the experience or reflect on what exactly they learned from it. 
• Similar to example 1, this introduction includes some clichés which detract from the author’s overall message. For example, that they have wanted to do medicine from a young age or that they love science (with no further explanation as to why). 
• It is far too long. Again, an introduction should be a succinct summary of why you're interested in medicine, and not a brief account of all of your experiences.

The stronger parts of this introduction include the following:

• The author does demonstrate that they can reflect on the skills they’ve improved through experience. For example, the analytical and problem-solving skills they gained from chemistry.
• The candidate shows an understanding of the link between evidence-based science and clinical application when discussing how they did further research around their physics course. This shows a good level of curiosity and insight.

'I first became interested in studying medicine when I carried out a work experience placement with my father an elderly care specialist. I really enjoyed the experience and it gave me a deeper insight into the challenges doctors face. I now believe that I better understand the resilience - both mental and physical - that doctors need to cope with the heavy workload and emotional challenges. A few months ago I was given the opportunity to attend work experience in St Mary’s hospital in Manchester where I visited and observed many different specialties and areas of the hospital like A&E and the labs and witnessed how doctors carried out their jobs. For the past year I’ve been doing some other volunteering work too, such as, taking meals around to patients on the ward, asking them about their experience in the hospital and just chatting with them about how they’re feeling. They’re often delighted to have someone to talk to especially during Covid when they weren’t allowed to receive visitors. I saw how my communication and empathy made a real impact on the mood of the lonelier patients. I spent a few days working in the same hospital, shadowing doctors and Allied Health professionals in the stroke ward. I became much more familiar with the process doctors used for treating stroke patients, and developed an understanding of the role that physiotherapists and occupational therapists have in their rehabilitation. On top of that I organised a placement with the emergency medicine doctors and spent time in the haemapheresis unit at St Mary’s.'

This example does contain some of the features we look for in a complete main body section but could definitely be improved: 

• The main issue with this is the list-like presentation, which goes hand-in-hand with a general lack of reflection or insight. Although it is good to discuss your work experience in your personal statement, it would be far better if the candidate focused on just one or two of the experiences mentioned, but went into far more detail about what they learned and the insight they gained. For example, after mentioning the role of Allied Health Professionals in the rehabilitation of stroke patients, they could go on to discuss how they came to appreciate the importance of these healthcare workers, and how the contribution of all these individuals within the multidisciplinary team is so important to achieving good outcomes.
• Statements like ‘I [...] witnessed how doctors carry out their jobs’ make it seem as if the candidate really wasn’t paying attention. They need to explain what they mean by this. Were they impressed by the doctors’ effective teamwork and communication skills, or perhaps by their positive attitude and morale? Did they seem well-trained and effective? What did they learn from this that might help them in the future?  ‍
• Similarly, the student simply states that they saw the effect of empathy on patients: ‘I saw how my communication and empathy made a real impact on the mood of the lonelier patients.’ This adopts a ‘telling’ approach, when the student needs to adopt a ‘showing’ approach. Simply telling us that they saw something does not adequately demonstrate an understanding of why those qualities are important, or what they actually mean. What does it mean to have empathy? What does that look like in real terms? How did they use it? What was the effect? Showing the tutor that you are empathetic is important, but simply saying it is disingenuous and shows a lack of understanding.
• The candidate spends a number of characters name-dropping the exact hospital they visited and its location, which isn’t the best use of valuable space, as it has no real impact on the message they’re trying to convey.
• Generally, it isn’t a good idea to talk about work experience with family members. Of course, this might be the reality, but try to have some other placements that you’ve organised yourself so that it doesn’t appear as if your family are doing all the hard work for you. At the very least, you could simply leave this information out.
• There are a few grammatical errors here, especially regarding the use of commas. It’s important to use a spell checker or to ask an English teacher to check your work for you before submitting your statement.

The better features of this example are:

• The candidate does show some insight into the role of a doctor when they talk about the resilience required by doctors to cope with the hard hours and challenging conditions. They just need to reflect in this way in other parts of the section, too.
• The author has clearly done a lot of work experience and is right to discuss this in their personal statement. Just remember that you don’t need to squeeze in every single little placement.

'I was pleased to be appointed as head boy in my last year of school, and as part of this role I headed up the school safety office. I carried out inspections of the dormitories, roll calls and helped in the running of school festivals and activity days. The office I was in charge of needed to ensure the safety of every student in the school and I helped plan and lead drills to prepare the students for storms, floods and fires. This role has made me a far better leader, and I also believe that I am now far more calm and logical when working under pressure or in uncertain situations. I’ve been an editor on the online school blog for over 2 years now and the experience has taught me how to work effectively in a team when under time pressure. In order to meet my deadlines I needed to remain motivated even when working independently, and I think that the diligence and work ethic I’ve developed as a result will be incredibly useful to me as a medical student. I took on the role of financial director for both the table tennis club and Model United Nations at my school. At first I struggled with the weight of responsibility as I was in charge of all of the clubs’ money and expenditures. However, I am now a far more organised individual as I came to appreciate the value of concise paperwork and of keeping a record of my actions. I not only manage the funds of the table tennis club but am also a regular member of it. I often play independently, and the lack of a specific coach means that I have to identify my own strengths and weaknesses. I am now far better at being honest about my weaknesses and then devising strategies for working on them. The sport has also allowed me to demonstrate my ability to work well in a team, but also to get my head down and work independently when necessary.'

This example is generally well written and showcases some of the features of a good main body section. However, there are some areas that can be improved:

• This section would benefit from the ‘show, don’t tell’ approach. Instead of explaining specific situations or events through which the candidate demonstrated certain attributes, they simply state them and then link them vaguely to a more general role or activity.
• The bigger problem, however, is that the author mentions a wide range of skills but falls short in linking these back to medicine.  ‍ For example, after reflecting on their role in the school safety office and the leadership skills they developed as a result, the author could talk about the senior role that doctors have within the multidisciplinary team and the importance of good leadership in a medical setting.  Similarly, the author mentions their ability to work independently but should really round this off by describing how this would benefit them in medical school, as the ability to progress your learning independently is crucial to success there. The student mentions an understanding of and proficiency with paperwork and recording their actions. Doctors must constantly do this when writing notes for each patient, so the candidate should really try to mention this in their statement to explain why their skills would be useful. The mention of teamwork could be followed by an explanation of why it is important in a medical setting and how the applicant witnessed this during their medical work experience. Finally, when the student talks about being able to identify and work on their weaknesses, they could use this as an opportunity to demonstrate further insight into the medical profession by discussing the importance of revalidation and audit in the modern NHS, or talking about how important it is for doctors to be able to work on their areas of weakness. 

Better aspects of this example:

• The applicant doesn’t simply list the activities they have been a part of, but also explains what they learned from these and the skills and attributes they developed as a result. This reflective ability is exactly what assessors will be looking for.
• The tone of the section is appropriate. The applicant doesn’t appear arrogant or over-confident, but at the same time, they manage to paint themselves in a good light, highlighting their range of skills relevant to medicine.
• This example uses the character count effectively. Unlike the earlier examples, almost all of the sentences serve a purpose and are succinct.
• They demonstrate a wide range of skills, most of which are very relevant to medicine.

' I am a resilient and empathetic individual and I think that I have the qualities to thrive despite the social and academic challenges of university. Through my work experience I’ve gained an insight into the difficulties doctors face but this has not dampened my enthusiasm. My placements and voluntary work have only strengthened my commitment and dedication to studying medicine.'

The effectiveness of a conclusion depends on the rest of the statement before it, so it is hard to judge how good a conclusion is without seeing what the candidate has mentioned in the rest of their statement. Assuming this follows on logically from the statement, however, we can say that this conclusion is generally good for the following reasons:

• It is brief, to the point, and highlights that the student holds some of the skills doctors need (this would of course need to be backed up with examples in the rest of the statement). 
• The author doesn’t introduce any new ideas here, as that would be inappropriate, but rather reiterates their determination, which is exactly what admissions tutors want to see. 
• The author demonstrates a balanced understanding of the demands of a medical career, illustrating this is a decision they have made rationally while considering the implications of their choice. 

As is always the case, this conclusion could still be improved:

• The mention of the social challenges of university is a bit too honest, even though these exist for everyone. Mentioning them could give the impression that the student struggles socially (which is not something they would want to highlight), or that they intend to dive into the social side of university at the expense of their studies. 
• If the candidate really insists on mentioning the social side, they should at least do this after discussing academics, and they should do it in the body of the statement, where they have space to explain what exactly they mean.
• The student describes themselves as empathetic. This should be avoided, as it should be evident from the statement itself.

'Over the years I have built up a large and extensive set of medical work experiences and volunteering opportunities. These have allowed me to demonstrate my ability to communicate effectively and work in a team, and they will allow me to become a more diligent student and effective doctor. I think that this, alongside my ability and strength of character mean that I should be considered for this course. I am excited to get started and begin to put my skills to good use.'

This is a reasonably strong conclusion. It provides a to-the-point summary of why the author believes they should be selected to study medicine and shows their excitement for starting this journey. However, there are some parts of this example that could be improved: 

• The author mentions 'ability' and 'strength of character.' These are nebulous terms and not specific to medicine or a medical degree in any way.
• The mention of a 'large and extensive range of medical work experiences' indicates overconfidence. Medical applicants are not expected to have any medical ability or any 'large and extensive range' of medical experience, nor is it probable that this candidate actually does (otherwise they wouldn’t need to go to medical school in the first place). Rather, medical students need a suitable set of skills and attributes in order to make the most of their medical education and become an effective doctor.
• On a similar note, the applicant says that their range of medical work experience will make them a better student and doctor, but this is only true if they can reflect on their experience and learn from it. Impassively watching an operation or clinic without properly engaging with it won’t make you a better doctor in the future.

We’ll now go on to look at an example of a strong personal statement. No personal statement is perfect, but this example demonstrates a good level of reflection, engagement and suitability to study medicine (we know this because the writer of this statement went on to receive four offers). 

It goes without saying that plagiarism of any of these examples is a bad idea. They are known to medical schools and will be flagged up when run through plagiarism detection software. 

Use these as examples of ways you could structure your own statement, how to reflect on experiences, and how to link them back to medicine and demonstrate suitable insight and motivation. 

'It is the coupling of patient-centred care with evidence-based science that draws me to medicine. The depth of medical science enthrals me, but seeing complex pathology affecting a real person is what drives home my captivation. As a doctor, you are not only there for people during their most vulnerable moments but are empowered by science to offer them help, and this capacity for doing good alongside the prospect of lifelong learning intrigues me. In recent years I have stayed busy academically - despite my medical focus I have kept a range of interests, studying Spanish and German to grow my social and cultural awareness and playing the violin and drums in groups to improve my confidence when working in teams and performing. This is similar to the team-working environment that dominates in medical settings, and I have found that my awareness of other cultures is a great help when interacting with the hugely diverse range of patients I meet during my volunteering work. The independent projects I am undertaking for my A-levels teach me how to rigorously construct and perform experiments, process data and present findings, developing my written communication. My work experience showed me the importance of these skills when making patients’ notes, and of course, medical academia must be concisely written and well constructed and communicated. Maths teaches me to problem-solve and recognise patterns, vital skills in diagnosis. Over the past two years, I have actively sought out and planned work experience and volunteering opportunities. My time last year in Critical Care showed me the importance of communication in healthcare to ensure patients understand their diagnosis and feel comfortable making decisions. I saw the value of empathy and patience when a doctor talked to a patient refusing to take her insulin and suffering from diabetic ketoacidosis. They tried to understand her position and remain compassionate despite her refusal. My experience deepened my insight into the realities of a medical career, as we were at the hospital for more than ten hours a day with breaks and lunches cut short by bleeps or calls from the ward. This helped me understand the physical resilience required by staff as I also came to appreciate the immense emotional burden they often had to bear. Despite this, the brilliant staff remained motivated and compassionate which I found inspirational. The Brighton and Sussex Medical School work experience and Observe GP courses I completed put emphasis on the value of holistic, patient-centred care, introducing me to specialities I had not previously considered such as geriatrics and oncology. Inspired by my experience I explored a variety of specialisms, reading memoirs (Do no harm) and textbooks (Oxford handbook of clinical medicine) alike. I investigated medical politics with my English persuasive piece, discussing the ethics behind the junior doctor strikes of 2016. I have been volunteering in a hospital ward since January, which helps improve my confidence and communication skills when talking to patients and relatives. I showed my ability to deal with unexpected situations when I found a patient smoking whilst on oxygen, and acted quickly to tell nurses. Over lockdown I felt privileged offering lonely patients some tea and a chat and seeing their mood change - it taught me that medicine is about treating patients as individuals, not a diagnosis. My work on the hospital door taught me to stay calm and interact assuredly with visitors, vital skills in public-service jobs like medicine. I coach tennis at a local club, planning and running sessions for younger children. I am responsible for players' safety and must manage risk while showing leadership qualities by making the sessions fun and inclusive. As a player, I am part of the self-run performance team, which forces me to better my ability without coaching. This means developing self-reflection and insight into my weaknesses, which I know to be integral skills for medics. One of the doctors I shadowed during my work experience was just starting her revalidation process and I saw the importance of self-awareness and honest reflection in meeting her targets and becoming a better doctor. I achieved my Gold Duke of Edinburgh certificate of achievement (and the Bronze and Silver awards), exhibiting my commitment and ability to self-reflect and improve. On our Silver expedition, we experienced severe rain, showing resilience by continuing when our kit was wet from day one. My diligence and academic ability will allow me to thrive in medical school, and I have the prerequisite qualities to become a compassionate and effective doctor. Despite the obstacles, I am determined to earn the privilege of being able to improve peoples' health. This is something that excites me and a career I would happily dedicate my life to.'

Strong personal statement example analysis

Introduction.

This statement is a good example of how a personal statement should be constructed and presented. The introduction is short and to the point, only dealing with the candidate’s motivations to study medicine while also demonstrating an insight into what the career involves. 

They demonstrate their insight briefly by mentioning that medicine involves lifelong learning. This is often seen as one of the challenges associated with the career but here they present it as an advantage which makes them seem more suited to the career. It also show they're a curious and interested individual who enjoys learning. 

The introduction's final sentence offers an opportunity for interviewers to probe the candidate further, to explore their curiosity, and ask them to explain what exactly attracts them to lifelong learning. An astute candidate would recognise this and try to think of a suitable answer in advance.

Paragraph 2 

The second paragraph opens the body of the statement by exploring the author’s academic interests. As with some of the previous example body paragraphs, the writer shows their reflective ability by explaining what each of their subjects taught them, and the skills they developed and demonstrated as a result. They improve upon this further by linking these skills back to medicine and explaining why they are important for doctors. 

This paragraph demonstrates the author’s work-life balance by showing their varied interests in languages and music, all without wasting characters by saying this directly. They also mention the diverse range of patients they encountered during their volunteering, which again implies an empathetic and conscientious nature while showing an insight into a medical career (particularly regarding the vast diversity of the patient cohort treated by the NHS). 

Their explanation of the relevance of maths could be more detailed, but again this could be something the applicant is hoping to be questioned on at interview. The candidate comes across as thoughtful and multi-talented, with the ability to reflect on their decisions and experiences, and with a suitable insight into how their strengths would play well into a medical career. 

In this particular paragraph, there isn’t much explanation as to how they drew their inferences about what a medical career entails from their volunteering and work experience (and what exactly these entailed), but these are explored in more detail later in the statement.

P aragraphs 3 and 4 

The next two paragraphs discuss the candidate’s work experience, beginning with a single work experience placement in detail. This is a better approach than the large lists of placements seen in the previous example body paragraphs. The author talks about a specific scenario and shows that they paid attention during their shadowing while also illustrating their ability to reflect on these experiences and the precise skills involved. 

The skills they mention here – communication, empathy, resilience – are skills that they specifically talk about developing and demonstrating through their activities in other parts of the statement. This shows that they have taken their learning and used it to inform the focus of their personal development. They also not only state that these skills are important for medics, but also explain why this is. For example, they explain that communication is important in helping patients relax and engage with their healthcare, and that resilience is required to deal with the antisocial hours.

In this section, the applicant briefly mentions a specific medical condition. This shows that they were engaging with the science during their placement and also provides interviewers with an opportunity to test the applicant’s scientific knowledge. Knowing this, the candidate would likely research diabetic ketoacidosis in order to be able to impress the panel. 

The author mentions some other virtual work experience opportunities they’ve been involved with and sets themselves up to discuss what these placements taught them. They then go on to explain the actions they took as a result of this, showing that they really engaged with the virtual placements and could identify what they learned and their areas of weakness. This is linked well to further reading and research they carried out, which illustrates their curiosity and engagement with medical science and literature. 

The reference to the junior doctor strikes at the end shows that they have engaged with medical news as well as the ethical side of medicine, which is something that many medical schools place a lot of emphasis on at interviews. Ideally, this section would explain how exactly they explored these different specialties and illustrate what they learned and how they developed their learning from the books mentioned.

Paragraphs 5 and 6 

These paragraphs discuss the applicant’s hospital volunteering and other extracurricular activities. The applicant doesn’t just state that they’ve volunteered in a hospital but goes into depth about the precise skills they developed as a result. They include an anecdote to illustrate their ability to react quickly and calmly in emergency situations, which is a great way to show that they’ve been paying attention (though this should really be backed up with an explanation as to why this is important in medicine). 

The candidate also shows their patient-centred approach when discussing how they cared for demoralised patients (again illustrating empathy and compassion). This style of healthcare is something that the modern NHS is really trying to promote, so showing an awareness of this and an aptitude for applying it practically will really impress your assessors. 

The author demonstrates another core attribute for medical students when talking about how their work on the front door of the hospital improved their confidence in communication, and they once more link this back to medicine. This last section could benefit from further explanation regarding the nature of their work on the hospital door and exactly how they developed these skills. 

In the second of these sections, the candidate simultaneously reflects on the skills they learnt from their tennis and explains how these apply to medicine, showing insight into the profession by mentioning and showing awareness of the process of revalidation. This will show assessors that the candidate paid attention during their work experience, reflected on what they learned, and then identified a way they could work on these skills in their own life.

The author name-checks the Duke of Edinburgh Award but then goes on to explain how exactly this helped them grow as a person. They link back to resilience, a skill they mentioned in an earlier section as being important for medics.

The conclusion is succinct and direct. Although clichéd in parts, it does a good job of summarising the points the candidate has made throughout the statement. They demonstrate confidence and dedication, not by introducing any confusing new information, but rather by remaking and reinforcing some of the author’s original claims from the introduction.

The following example illustrates how not to approach your personal statement. Now that you’ve read through the analysis of previous example passages and a complete example statement, try going through this statement yourself to identify the main recurring weaknesses and points for improvement. We’ve pointed out a few of the main ones at the end. You can even redraft it as a practice exercise.

' ‍ The combination of science with empathy and compassion is what attracts me most to a career in medicine. However, I wanted to ensure that the career was right for me so I attended a Medic Insight course in my local hospital. I enjoyed the course and it gave me new insight - the lectures and accounts from medical students and doctors helped me realise that medicine was the career for me. I was also introduced to the concept of the diagnostic puzzle which now particularly interests me. This is the challenge doctors face when trying to make a diagnosis, as they have to avoid differential diagnoses and use their skills and past experiences to come to a decision and produce the right prognosis. In order to gain further insight into both the positives and downsides of being a doctor, I organised some work experience in my local GP’s surgery. I managed to see consultations for chest pain, headaches, contraception and some chronic conditions which was very interesting. I also sat in on and observed the asthma clinic, which proved to be a very educational experience. During my experience, I tried to chat to as many doctors as possible about their jobs and what they enjoyed. I recently took up some work volunteering in a local elderly care home. Many of the residents had quite complex needs making it arduous work, but I learned a lot about caring for different people and some appropriate techniques for making them feel comfortable and at home. I became a better communicator as a result of my experience Nevertheless I really enjoyed my time there and I found it fulfilling when the patients managed to have fun or see their family. I appreciated how doctors often have high job satisfaction, as when I managed to facilitate a resident to do something not otherwise available to them I felt like I was making a real difference. My academic interests have also been very useful in developing skills that will be crucial as a doctor. I chose to study Physics and business at a-level and these have helped me develop more of an interest in scientific research and understanding; I’ve also become a more logical thinker as a result of the challenging questions we receive in physics exams. I know how important communication is as a doctor so I chose to study Mandarin, a language I know to be spoken widely around the globe. I was the lead violin in my school orchestra and also took part in the wind band, showing that I was willing to throw myself into school life. I really enjoyed our school’s concert, in which I had to perform a solo and demonstrate that I could stay calm under pressure and cope with great responsibility and i think that I’m now a better leader. This skill has also been improved in roles within my school on the pupil council and as form captain, which have improved my self-confidence. I needed to work hard in order to achieve my bronze and Silver Duke of Edinburgh awards, and have dedicated much of my time outside school to this endeavour over the past few years. I endured weekly sessions of Taekwondo, worked voluntarily in the charity shop Barnardo’s and took part in violin lessons.  As I’ve demonstrated throughout this statement I have an affinity for music, and so at university I plan to get involved with orchestras and bands. I also want to widen my horizons and discover new interests and hobbies, while trying to make new friends and cultivate a good work-life balance. I’m also keen to hike in the university’s surrounding territories. If I were allowed to study medicine, it would not only allow me to achieve one of my life goals, but to prove to you that I can become an effective, and successful doctor. I am absolutely dedicated to the study of medicine and know that I have the prerequisite skils and qualities to thrive in medical school and become a credit to your institution.”

Weak personal statement example analysis

• This personal statement does have some promising features, but overall it isn’t well structured and lacks appropriate reflection and insight. You can see this by comparing it to the strong example above. The author in this weak example very rarely describes what exactly they learned or gained from an experience and rarely links this back to medicine. 
• It reads quite like a list, with the candidate reeling off the experiences they’ve had or activities they’ve taken part in, without going into any real depth. They also use some vocabulary that implies that they really weren’t enjoying these experiences, such as when they speak of ‘enduring’ their time doing taekwondo, or of caring for residents being ‘arduous’ work. You don’t have to enjoy every activity you take part in, but implying that caring for people (a huge part of the job you are applying for and claiming to enjoy) is something you consider a chore isn’t a great start. This statement also has some questionable grammar and punctuation errors, which raises a red flag. Don’t forget to proofread your statement carefully before you submit it.
• The candidate often starts off their sections in a promising way. For example, by stating that they started volunteering in a local GP practice to gain more insight into the profession, but they rarely actually follow through on this. You never find out what insight the candidate actually gained or how they used this to inform their decision to apply for medicine. 
• Such lack of explanation and specificity is a theme throughout the statement. In the introduction, they say that personal accounts and lectures confirmed their wish to become a doctor, but they don’t actually explain how or why. They mention that their school subjects have helped them think more logically or improved their communication skills (which is good), but then they never go on to explain why this is relevant to medicine. They talk about leadership and self-confidence but again don’t link this back to the importance of self-confidence and the prominence of leadership in a medical setting.

To create an effective medicine personal statement, you need to provide plenty of detail. This includes concrete experiences demonstrating qualities that make a good doctor. If you can do this authentically, humbly and without selling yourself short, your personal statement will be in very good shape.

‍ ‍ If you're looking for more inspiration to craft a compelling medicine personal statement, check out our Personal Statement Online Course . It has over 100 personal statement examples, in-depth tutorials, and guidance from admissions experts, to help you create a ready-to-submit personal statement in just three days.

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Medicine Personal Statement Example 1

This Medicine Personal Statement was successful for Imperial, UCL, QMUL and King's.

• Deciding on Medicine
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• Medicine Personal Statement Examples
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• How to Structure a Personal Statement
• How to Write a Personal Statement
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• Studying Abroad
• Study Medicine Abroad In Europe
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• How To Survive Your First Year Of Med School
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Have a look at this successful Medicine Personal Statement example for inspiration to help you plan and structure your Personal Statement .

Medicine excites me; it is full of unanswered questions, unsolved problems and potential for growth. It is a limitless field, exploring everything from our biochemistry to our birth and death. Ultimately, however, the relationship between doctor, patient and community alongside the academic inquiry cements my passion for medicine.

My experience volunteering with St John Ambulance over the past 4 years means that I have had to build my own relationships with patients. Over time, I have become more confident and more relaxed about having – sometimes intimate – conversations with patients. For example, one long conversation allowed me to differentiate between heat exhaustion and an undiagnosed stomach ulcer, and another led to the discovery that a young woman’s unusual bruising was from her job as a beekeeper.

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Again, the importance of communication in medicine was echoed in a work experience placement with the Northern Medical Centre, a central London GP practice . The doctor I was shadowing had to talk to her patient in Mandarin while simultaneously typing patient notes in English. I observed the real barriers to successful medical practice in a multicultural community and learnt that the most effective solutions were aided by discussions with patients, who already knew what wasn’t working and what might help. I found it fascinating to see how simple changes, such as inviting multiple family members to consultations, could make a big difference. I was interested to see how this was formalised by medical behavioural economics, which investigates how ‘nudges’ can significantly improve clinical outcomes.

During a hospital placement in gastroenterology at UCLH, I was able to see medical decision-making for myself in an MDT. I was impressed by the efforts of consultants to utilise the diverse skills in the room, using the meeting as an opportunity to liaise with multiple specialists. I was surprised to see that many patients had multiple unrelated conditions that straddled many medical disciplines. There is, I realised, growing room for new specialities on the cutting edge of medicine – one doctor I spoke with had effectively created their job as a consultant neurogastroenterologist. The connections between such disparate fields of medicine and how they come together to help and treat patients intrigue me.

My curiosity piqued, I then went on to look into the gut-brain axis in more depth. I was particularly fascinated by the aetiology of depression, in which gut microflora seem to play a potentially significant role. I particularly enjoyed ‘The Second Brain’, which gave me a deeper understanding of the enteric nervous system, helping me to understand how the gut can have such devastating effects on mental and physical health, and vice versa. This interplay between biological and psychological factors in disease is, for me, one of the most fascinating relationships in medicine. It is one of medicine’s current frontiers, with incredible potential for new discoveries that will improve patients’ lives.

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I have also found that an understanding of my own psychology is valuable. Working long shifts with SJA has shown me how difficult it can be to recognise how tired or stressed you really are, especially when exhausted. Taking breaks and truly relaxing is important for me. Through my rowing and coxing I can unwind and forget everything but the river. I am very protective of my rowing and reading time. I also try to keep the words of the poet Horace in mind: ‘carpe diem, quam minimum credula postero’. 

Medicine is a dynamic, compelling and caring field that I cannot wait to be a part of. I can think of no other ancient practice that has been so changed by modern life, and which is yet rooted in the same principles of kindness, competence and respect. I sincerely and eagerly look forward to following in this tradition.

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Residency Personal Statement: The Ultimate Guide (Example Included)

A step-by-step medical residency personal statement guide to help you match into your dream program.

Part 1: Introduction

Part 2: brainstorming topics for your personal statement, part 3: how to write an amazing residency personal statement, part 4: in-depth analysis of a full-length personal statement example, appendix: frequently asked questions.

Applying to medical residency programs isn’t exactly easy. After four years of medical school, and years more spent before that preparing for medical school, you’re probably ready for a breather. But residency applications hit you with everything from USMLE scores to Medical School Performance Evaluations (MSPEs). The uncertainty leading up to match day can be stressful and anxiety inducing—will your near-decade of work pay off?

Thankfully, the residency application process is fairly transparent—we know what the most important aspects of the residency application are. Every two years, the NRMP’s Program Director Survey reveals which factors are cited as the most crucial components of your residency application and are thus the core deciders for whether or not you’ll get an interview. Though the exact ranking varies from year to year and according to specialty, typically you’ll find USMLE scores, letters of recommendation from physicians in your targeted specialty, and MSPEs hovering at the top.

But these materials may not express what drew you to the specialty in question or what got you into medicine in general. And though it can seem as if programs are overwhelmingly interested in your scores and evaluations, they are also interested in the person behind the grades.

In this guide, we’ll discuss the factor that was fourth-most cited by program directors on the NRMP’s 2020 survey: the residency personal statement.

Before we get into the step-by-step guide, we’ll offer some general framing thoughts. Being able to communicate your motivations and personality through your application, especially your personal statement, bodes well for your ability to bring that same enthusiasm and drive as a resident and in the rest of your career as a physician, so take note. 

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Why does the residency personal statement matter?

The personal statement is an essay of about a page (one page in ERAS is 3,500 characters including spaces) in which you articulate who you are and why you want to enter a certain specialty. It’s your big opportunity to set yourself apart from other applicants by highlighting anything that isn’t well represented in other parts of your application but that nevertheless contextualizes your CV and accomplishments. This context could include interesting life experiences and motivations for pursuing a given specialty. 

There’s a good reason the personal statement is relevant for program directors. Because so much of the information that programs have to determine whether you’ll be a good fit is quantitative in nature, it’s likely that programs will receive many applicants who have similarly competitive scores and grades. What can serve as a tiebreaker?

Letters of recommendation offer qualitative information. But the personal statement is the main opportunity for you to directly make a case for yourself, on qualitative terms, before you attend residency interviews .

The personal statement can also weed out applicants who don’t demonstrate an adequate understanding of their specialty of interest or who come across as pretentious and pompous. For this reason, in addition to the basic requirements of proper grammar and spelling, you’ll need to strike the right tone with your essay: seeming aware of your motivations and accomplishments to date, passionate about what you hope to achieve in the specialty, and also humble.

Remember: a great personal statement cannot save an otherwise weak application, but a poor one could hurt an otherwise strong application.

What should the personal statement accomplish?

The residency personal statement should include and reflect:

What draws you to the specialty

The skills or qualities that will help you succeed during the residency and as a practicing physician

Your long-term plans, what you hope to accomplish, and your preferred setting

Personal attributes that make you well-suited to the specialty and training

What attracts you to a particular program (if you’re applying for a specific program outside of the national matching system or if you customize a personal statement within NRMP) 

Ultimately, the combination of these elements will give program directors a sense of the kind of colleague you would be and how you would fit into their program.

Meet our students

Throughout this post, we’ll provide examples from students who have gone through this process so you can see their writing in action.

Roger: Roger immigrated from Mexico as a teen and attends a medical school in a rural area. His path to medicine wasn’t straightforward. After graduating from high school, he worked for several years in construction, quickly climbing the ranks to become project manager for a small roofing firm before deciding to go back to school. He hopes to specialize in dermatology because, after growing up in poverty and performing blue-collar work for years, he wants a comfortable life that will allow him to focus on his growing family. 

Mohana: Mohana entered medical school believing her path was pediatrics. But after an away rotation in radiology, she’s leaning toward radiology, having become attracted to the more technical aspects of the field and its work-life balance. After years of schooling, Mohana mostly wants time for her musical hobbies.

Cynthia: Cynthia either wants to work at a research hospital or practice gynecology. She thinks she could be happy with either, but knows she’d be happiest if she could do both. She also received an MPH before attending medical school. Cynthia still has a taste for social justice, but it isn’t always evident on her CV.

Kazuo: Kazuo initially wanted to pursue thoracic surgery, but after spending time with surgeons, he decided the culture was not for him. Now he’s certain he wants to pursue anesthesiology, and isn’t entirely sure how to convey his interest. He is worried this change of heart may hurt his chances of matching into his top programs.

Brainstorming topics

Before you begin writing, set aside time to brainstorm. Whether you have an idea in your head or are struggling with where to start, freeform thinking can expand your options, call to mind experiences you hadn’t considered, or even help you pick unique interests you otherwise might have left out.

If you’re uncertain of how to proceed, jot down your answers to the following questions:

What first drew you to medicine?

Was there an experience, clinical or otherwise, that had a significant impact on you? What was it and why is it meaningful?

When did you know you wanted to pursue the specialty in question? What attracted you to the specialty?

What are your greatest qualities? When have you demonstrated these qualities?

Where do you see yourself 20 years into your career as a physician?

What’s an important part of who you are that isn’t on your resume?

Who are your role models and why?

What are your most meaningful extracurricular activities? Why?

What’s an accomplishment you are most proud of?

What was your most enlightening moment?

What medical cause do you care about most, and how did you come to care about it?

These are just a few questions to get started. Add more as they occur to you.

Another way to approach the personal statement is to ask what qualities make a good physician in your target specialty and consider how you embody those qualities. For example, here are a few qualities that might represent pediatric neurology: 

Strong communication or interpersonal skills

Attentiveness

Technologically inclined

Passion for advocacy

Ingenuity 

After brainstorming, take anywhere from a few hours to a day or a week to step away from your notes. This will help you as you move onto the next step: focusing your ideas.

Focusing your ideas

Here are some sample topics our residency applicants came up with:

An accidental run-in with poison ivy

Advocating for his Spanish-speaking roofing clients

Adjusting to the U.S. after immigrating from a small town in Mexico

Teaching herself MaxMSP programming skills

Babysitting her nieces and nephews

Her away rotation in radiology

Giving sex-ed talks in local middle schools

Being a surrogate daughter for her next-door neighbor, Leticia

Presenting her research findings at conferences

Kazuo  

His ten-year meditation practice

His experience in surgery rotation

Admiration for his father, who taught him darkroom photography

Once you’ve generated your list of ideas, consider how they do or do not compellingly answer the following questions:

Why this specialty?

Before writing your personal statement, you should be very clear, personally, on why the specialty you’ve chosen is the right one for you.

Program directors want to know that you have a realistic idea of what your specialty will entail. For instance, you might be interested in plastic surgery because it’s a highly paid field but fail to understand the importance of artistic anatomy in its practice. If your application fails to convey compelling reasons for pursuing a specialty beyond high salaries or the potential lifestyle benefits associated with it (especially true for specialties like radiology and dermatology), it may cost you an interview invitation.

(Suggested reading: The Most Competitive Medical Residencies: A Complete List )

What strengths do I have that are not apparent in my other application materials?

Though your recommenders may offer a sense of your personality and interests, you are in the best position to include meaningful details that can’t be found on a CV. What aspects of your life do you think might compel a selection committee to pick you over other applicants? What makes you unique?

How do I embody the qualities of a good physician in the specialty?

This is slightly different from understanding the realistic requirements of a given specialty. Instead, it joins the strengths of your full life to the characteristics of an exemplary practitioner in your field of choice. 

For instance, an anesthesiologist who performs their role well may go unnoticed by a patient, whereas a pediatrician who is too technically inclined may come across as cold or uncaring. The decisiveness of a surgeon in the OR is distinct from a psychiatrist adjusting a patient’s depression medication through trial and error over time. Make sure that the details you select speak to the qualities of your chosen specialty.

Let’s look at how our students applied these principles.

With two young children and another on the way, Roger wants good work hours and enough money to give his children a high quality of life. He’d never thought much about dermatology until he had accidental contact with poison ivy and took an elective in the specialty. Also, Roger hopes to practice in a rural setting because the low cost of living would facilitate his family-oriented lifestyle, but he knows he must communicate a more selfless reason in his personal statement. Roger’s approach will combine seemingly unlike things (roofing, dermatology, advocacy for rural patients) into one cohesive portrait of who he is and what matters to him.

Mohana doesn’t list her hobby on her resume, so writing about it for her personal statement will illuminate a side of her that neither quantitative scores nor letters of recommendation can comment on. Programming beats is Mohana’s passion, and she wants to show off how her technical prowess can serve her in the field of radiology.

But what to make of her experience babysitting her nieces and nephews? For Mohana, childcare helped her learn that she was particularly adept at soothing children in unfamiliar situations. It isn’t her strongest idea because she’s primarily interested in diagnostic radiology but including it may convey to program directors that she understands that radiology remains as patient-centered as any other medical discipline. 

So far, Roger and Mohana are using their experiences to tell a story, not just enumerate things they’ve done. At the end of the day, great personal statements tell stories—about you, your journey, and why you’re right for a given specialty. If your idea is a topic without a story, it’s not worth mentioning.

Questions to determine if an idea can be a story:

Can you reference a specific anecdote (a day, a summer, an interaction)? Can you include significant details that convey the specificity of what you experienced?

Is yours a story no one else could tell? You want a story that, even if someone had the same jobs, schools, or extracurricular activities as you, they would not be able to write in the same way.

Does the narrative have an arc? Do you demonstrate growth and insight over a period of time?

Is the voice of the essay yours? Is the language lively?

Regardless of the idea, you should be able to answer yes to at least one of these questions.

To that end, while Cynthia felt that her positive experiences presenting her research at conferences best expressed her passion for research, this information was readily available on her resume and could be a sentence in her personal statement, not an entire framing narrative.

On the other hand, Cynthia’s experience serving as a “surrogate” child for her neighbor, Leticia, could be used to encompass her interests in reproductive health, patient advocacy, and gynecology. Leticia, an elderly woman who had never had children of her own, was sterilized without her consent while receiving an appendectomy as a teenager in the 1960s. The injustice of this fueled Cynthia throughout her medical education.

Similarly, Kazuo thought his experience in the operating room was a natural place to begin: it was where he discovered he did not want to be a thoracic surgeon after all, but an anesthesiologist. But to convey a greater sense of his levelheadedness and exactitude, he chose to also talk about his role model—his photographer father—and the lessons learned in darkrooms and meditation, neither of which could readily be written about by another applicant.

Start with an outline

With so many great ideas and a narrative in mind, you might be tempted to start writing your essay now. But an outline will keep your ideas organized and help you write more efficiently. Even if you don’t start draft one with an outline and instead just “vomit draft,” consider making draft two a reverse outline so that at some point you have structure guiding you.

Here’s one path to follow:

First paragraph: Lead with detail

The residency personal statement is short—under 3,500 characters—and this brevity creates constraints. While an opening anecdote is a good approach to hook readers, you may choose to describe a situation or an experience more generally to accommodate the brevity.

Both options are possible, but what you choose depends on the anecdote in question and what you hope to accomplish over the course of the statement. The point is to pin your unique story to your interest in medicine by the end of the first paragraph if you can, but at the very least by the end of the second paragraph.

How do you choose your opening story? One way is to check against the questions above: Can you remember specific details? Is it something only you could write? Is there an arc or will there be one over a few paragraphs, even the whole essay?

Kazuo has a specific anecdote in mind for his hook: the first day of his surgery rotation. As you’ll see, the essay passes the specificity test by the strength of its details—an ovary riddled with cysts, the bright OR light, the origins of Kazuo’s surgical interest, the introduction of the father as a character—and sets Kazuo up to discuss how he came to be interested in anesthesiology. 

One of the most powerful moments in my medical education occurred during an oophorectomy. As Dr. Srivastava removed a cyst-riddled ovary, I noted that his calm was contagious; I felt focused but at ease. The surgery finished without a hitch. In fact, it was anticlimactic, even unremarkable. Having dreamed of becoming a surgeon since age 16, when my father had to undergo emergency surgery after a heart attack, it was a let-down. But my photographer father’s words on darkroom printing—“Look at the shadows, and they will guide you”—made me reconsider. When I looked away from the bright overhead light, I saw the reason for our calm: our anesthesiologist, Dr. Grant, had been silently watching the whole time, making sure the infusion was working as planned. 

Roger, on the other hand, describes a situation that conveys the roots of his advocacy.

 As a young roofing project manager, I chose to work with Spanish-speaking clients with roofs leaky from hailstorms many years prior. Because I was born in Mexico and had spent my younger years there, I felt a special connection when aiding non-English-speaking families who otherwise may have had difficulty navigating a complex insurance process to restore their damaged homes. I spent hundreds of hours learning to inspect and scrutinize the sometimes subtle, timeworn signs of hail damage to expertly advocate for those families. It was this love of advocacy, combined with my later love of biologic systems, which drew me to medicine. 

By distilling the career wisdom of years into one crystal clear statement about the relationship between allyship and medicine, Roger is anticipating an arc he will develop across the length of the essay while setting himself apart from his more traditional colleagues.

Body paragraphs: Connect your narrative to a thesis

Roger has, by the end of the first paragraph, indicated what drew him to medicine in the first place. This is a good approach, and a model that works for articulating the thesis for the specialty as well. 

Mohana gives her thesis in her second paragraph. Her opening anecdote was about how playing her first MaxMSP composition for friends was the culmination of hours of online tutorials and technical discussions on programming forums.

She describes the elation she felt at seeing her creation come to life for others and the satisfaction she received from sharing a common language with those who like learning through doing. This anecdote conveys something about Mohana’s personal qualities but doesn’t mention medicine at all. 

That’s where her second paragraph comes in. 

My passion for making music machines and my interest in radiology are fraternal twins. I want to be a radiologist because it would put my analytic skills to use just as trouble-shooting atonal compositions compelled me to search for answers. As someone who enjoys collaboratively finding creative solutions to seemingly intractable problems, I am especially suited to being a “doctor’s doctor”—a radiologist. I love talking shop with knowledgeable colleagues. Establishing a common diagnostic vocabulary with fellow clinicians intrigues me most of all. In fact, my radiology rotation felt like a real-life MaxMSP forum except that, instead of collectively developing an audio patch, we jointly scrutinized sagittal reconstructions for complex fractures.

Connect the personal to the professional

Having described the impact of growing up next door to Leticia, Cynthia connects that personal story to how she envisions moving forward in her professional life in her third paragraph. She also takes the opportunity to make a case for both research and clinical practice, giving herself a flexible statement that could suit a variety of program environments.

As I researched sources of misdiagnosis among OB/GYNs, particularly pertaining to endometriosis and hormonal disorders, I was driven by memories of Leticia. She once described how it took her ten years after her forced sterilization to understand the female reproductive system enough to comprehend what had been taken from her. As an OB/GYN, I would make sure no patient left my examination room without a clear understanding of her reproductive health. Moreover, the sex-ed I do in Baltimore middle schools has inspired me to share my research findings through outreach. Over time, my clinical and research experiences will give me the authority to advocate for reproductive health education reform. It is my ultimate goal to ensure that no young woman suffer as Leticia did. 

Demonstrate change and growth over time

One way to keep a personal statement reader engaged is by using the tried and true storytelling methods of conflict and resolution. Put another way, things have to happen—specifically, they have to change.

Body paragraphs are the perfect place to develop these transformations. What events incited your growth? How are these shifts related to your interest in pursuing a specialty or the kind of practitioner you will be?

Kazuo, for example, reckoned with the realization that surgery proper was not for him. But rather than consider this a failure of direction on his part, Kazuo uses this to his advantage, spinning it as a successful reorientation that more closely aligned with his experiences and values.

I was excited to alternate between preoperative procedures and pain management in the anesthesiology rotation. Some tasks felt familiar; assisting the attending in diluting medications called to mind the exact ratios I once mixed for my father’s developer and fixer so that his prints expressed the full gradient between black and white. Other tasks, like induction and the occasional corrections required for maintenance, were foreign. But the beeping monitors and visual cues entered my mind like the thoughts I’ve aimed to consider without fear or anxiety in my ten years of meditating. By honing my attention in darkrooms and in silent morning meditations, I’ve become attuned to others, often anticipating the needs of recovering patients before they can articulate these themselves. My anesthesiology rotation helped me understand that behind every unremarkable surgery was a great deal of foresight and diligence. These are the qualities I enjoy exercising most.   

Notice how Kazuo includes personal biographical details and establishes their relevance to anesthesiology. Interests aren’t mentioned just for the sake of mentioning them. They have been selected because they illuminate some aspect of Kazuo, whether it’s his longtime—and personally meaningful—interest in mixing solutions or his mindfulness. 

More importantly, however, is that these align with the qualities of a good anesthesiologist. For Kazuo, an anesthesiologist should not merely be reactive, but proactive, “anticipating the needs of recovering patients before they can articulate these themselves.” By the last line, Kazuo’s body paragraph is in conversation with his opening anecdote. In fact, Kazuo has demonstrated a transformation from the naïve student in the surgery rotation to the attentive, proactive, and self-aware anesthesiologist-to-be.

Communicate the kind of specialist you hope to be

Kazuo wants to exercise his foresight, diligence, and calm. Mohana wants to be a “doctor’s doctor.” Here are how Cynthia and Roger express the qualities they would like to respectively embody. 

I want to take the expertise I gain in my OB/GYN practice and reproductive health research and apply it in policy.  

Short, sweet, and to the point. Roger chooses to convey his ultimate goals in his conclusion, which can also be an acceptable approach if your essay’s structure invites it.

I intend to apply my passion for human connection and community to providing high-quality dermatologic care and research to communities which have traditionally had difficulty accessing care.

In one sentence, Roger synthesizes the different facets of his interest in dermatology and returns to the advocacy he first mentioned in his intro paragraph.

Conclusion: Tie it all together

Your concluding paragraph should leave selection committees with an understanding of who you are and why you’re applying. There are several ways to think about an ending to successfully avoid falling victim to clichés:

Don’t pre-write your ending. Some people have deeply ingrained ideas of what an essay’s conclusion should accomplish and can even write with a conclusion already in mind. However, it’s best to let a conclusion naturally respond to the elements in the essay, so don’t force it.

Avoid declarative sentences. Program directors see it all the time: “And that’s what would make me a great oncologist” or “I would bring these skills to your program.” Don’t let their eyes glaze over. Write something more unique.  

Consider ending on an image or with a callback to where you began the essay. This is one of the most organic and satisfying ways to conclude any piece of writing. Mohana’s essay, for instance, opens with playing her music for others. She closes with the following.

There is a joy in finding your tribe. I’m lucky to have several. The wider world of musical programmers is my creative community and the radiology team at Beth Israel Deaconess is an example of my ideal medical community. Whether creating a neural network for note generation or exploring new possibilities for interventional radiology, I know my fascination with innovation, technique, and diagnosis will help me find harmony between invention and the tried-and-true backbone of medicine–excellent patient care. People-centered radiology–that’s music to my ears.  

After you’ve finished the first draft of your residency personal statement

First, celebrate! Writing is hard no matter what, and the fact that you’ve accomplished anything with language is no small feat. But you’re just getting started. Settle in for some revisions:

Read your essay aloud. This will alert you to typos, problems of pacing, and issues of form that you might otherwise miss. Reading aloud also helps you get a sense for your essay’s voice—it should sound like you when read aloud.

Ask for feedback . You should have a trusted peer, professor, specialty advisor, or admissions counselor read your essay. The core question to ask them is, “Do you have a good sense of who I am and why I want to pursue this specialty after reading this?” If the answer is no, revise, revise, revise.

For big changes, don’t edit—rewrite. It can be a pain to invest so much time into a draft only to scrap it, but if you decide on structural revisions or major changes in content, start with a new document. Starting anew may give you a more cohesive and coherent final product. This doesn’t mean all your hard work was in vain. Print out a hard copy of your original, keep it on the table beside you, and open a clean doc. Drawing from your previous draft for your revision will ensure you have one essay at the end, not two spliced together.  

Before we go into our analysis, consider reading the personal statement example in its entirety. As you go through it, keep the following questions in mind: 

Does Roger demonstrate an understanding of his specialty of interest, including the kind of qualities an exemplary resident in the specialty must possess? If so, which ones?

Does Roger tell a story about how his interest developed? How does Roger demonstrate growth and change?

Could anyone have written this statement, or is it unique to Roger?

After reading the statement, do you have a good sense of who Roger is and why he wants to pursue dermatology? 

Let’s look at the dermatology statement Roger produced based on the process we described.

As a young roofing project manager, I chose to work with Spanish-speaking clients with roofs leaky from hailstorms many years prior. Because I was born in Mexico and had spent my younger years there, I felt a special connection when aiding non-English-speaking families who otherwise may have had difficulty navigating a complex insurance process to restore their damaged homes. I spent hundreds of hours learning to inspect and scrutinize the sometimes subtle, timeworn signs of hail damage to expertly advocate for those families. It was this love of advocacy, combined with my later love of biologic systems, which drew me to medicine. 

In medical school, I serendipitously found the specialty within which I wanted to apply this passion after accidentally dumping a bag of mulched poison ivy on my head. The resulting rash was painful but interesting and sparked a curiosity in cutaneous manifestations of disease that later led me to a dermatology elective. There, I was impressed by the dermatologist’s keen eye for detail, and I found the diagnostic challenge and the detail-driven expertise to be both fascinating and rewarding.  

Each new rash I saw was reminiscent of inspecting leaky roofs and I wanted to emulate my new mentors, who had developed the ability to diagnose and treat skin disease based on the subtle cues they saw. Such was the case when a grizzled farmer from a distant rural community with infrequent follow-up ascribed a sore on his arm to a specific trauma. Despite this history, the dermatologist recognized some subtle and suspicious features, prompting a biopsy that later showed invasive squamous cell carcinoma. In addition to the dermatologist’s diagnostic acumen, it was her relationship with the patient and her understanding of his community, values, and risk factors that allowed her to guide this patient to a better outcome.

In medical school I have enjoyed caring for those who, for cultural, insurance, or geographic reasons, have difficultly receiving care. After one shift in my inpatient pediatrics rotation, I brought my guitar to play for a Latino boy who was dying from leukemia and made his parents my favorite recipe for chile verde with pork. Although I couldn’t offer any more to them medically, I hoped to aid the fear and disconnection they had expressed with the unfamiliar environment now surrounding them. The connection made in that moment helped ease their suffering and fostered a better union between the treatment team and patient.

Multiple studies have suggested that outcomes for dermatologic conditions tend to be poorer in certain demographics. As part of my own research, I have begun investigating these disparities. This has included a research project where we evaluated the effects of social and demographic factors on melanoma outcomes. One finding that spoke to me was that outcomes tended to be poorer in areas with fewer dermatologists. Having grown up in a small town and having completed medical school in a more rural area, I feel a special connection to these communities. I hope to continue to engage in research that better elucidates these disparities to supply better care to these populations.

In my career I intend to apply my passion for human connection and community to providing high-quality dermatologic care and research to communities which have traditionally had difficulty accessing care. Training at your program would enable me to meet these goals and effectively treat and advocate for these patients. 

(Word count: 563; Character count: 3,498)

Residency personal statement analysis  

Let’s analyze the entire personal statement section by section and answer the questions posed above.

Introduction  

As a young roofing project manager, I chose to work with Spanish-speaking clients with roofs leaky from hail storms many years prior. Because I was born in Mexico and had spent my younger years there, I felt a special connection when aiding non-English-speaking families who otherwise may have had difficulty navigating a complex insurance process to restore their damaged homes. I spent hundreds of hours learning to inspect and scrutinize the sometimes subtle, time-worn signs of hail damage to expertly advocate for those families. It was this love of advocacy, combined with my later love of biologic systems, that drew me to medicine.

Roger leads with details like “roofs leaky from hail storms” and “time-worn signs of hail damage” that make his previous career in construction vivid in the reader’s mind. The specificity also ensures that only Roger could write an introduction like this. He indicates the hundreds of hours he spent learning to examine subtle signs of roof damage in a manner that suggests, without stating it outright, both the kind of learner Roger would be as a dermatology resident and the transferable qualities he gained from his work and life experiences.

The last line of the paragraph, which helps anchor the reader in Roger’s motivations from the beginning, describes how Roger’s interest came to be. This thesis makes it much easier to navigate the essay and helps Roger compellingly articulate who he is and why he has chosen to apply for dermatology.

Body section 1: Specialty

In medical school, I serendipitously found the specialty within which I wanted to apply this passion after accidentally dumping a bag of mulched poison ivy on my head. The resulting rash was painful but interesting and sparked a curiosity in cutaneous manifestations of disease that later led me to a dermatology elective. There, I was impressed by the dermatologist’s keen eye for detail, and I found the diagnostic challenge and the detail-driven expertise to be both fascinating and rewarding. 

In this section, Roger emphasizes his interest in dermatology and develops the idea he introduced in his opening paragraph: being attuned to subtle signs of damage. Roger finds kinship in the dermatologist’s “keen eye for detail,” relishes the “diagnostic challenge,” and emphasizes “detail-driven expertise”—all qualities he previously expressed about himself as a roofer and which he is now connecting to dermatology as a field.

In the second specialty paragraph, Roger turns his attention to a mentor to tell a specific anecdote that demonstrates his clear understanding about what dermatology entails. With his point about the visual and attentive elements of dermatology made, Roger transitions to describing the patient relationship toward the end of the second paragraph. The “understanding of his community, values, and risk factors that allowed her to guide this patient to a better outcome” sets Roger up to describe how he shares this awareness as well.

Finally, the specificity of the mulched poison ivy, its resulting rash, and the grizzled rural farmer makes this firmly Roger’s and no one else’s.

Body section 2: Advocacy

In medical school I have enjoyed caring for those who, for cultural, insurance, or geographic reasons, have difficulty receiving care. After one shift in my inpatient pediatrics rotation, I brought my guitar to play for a Latino boy who was dying from leukemia and made his parents my favorite recipe for chile verde with pork. Although I couldn’t offer any more to them medically, I hoped to aid the fear and disconnection they had expressed with the unfamiliar environment now surrounding them. The connection made in that moment helped ease their suffering and fostered a better union between the treatment team and patient. 

In this section, Roger returns to the advocacy he mentioned in his introduction. He keeps it unique by describing a specific interaction with a single family and even mentions his favorite recipe, which gives the body paragraphs a touch of his personality.

The cultural angle helps remind the reader of the ways Roger has been interested in culturally-specific service since his days in roofing, when he advocated on behalf of Spanish-speaking clients. 

Finally, Roger gives context to the research on his CV by showing how his preference for the underserved isn’t merely an ideological commitment. Rather, Roger’s attraction to dermatology dovetails with his passion for connecting with the underserved because his research credentials back it up. Even his upbringing in a different country finds a parallel in the rural environment where he hopes to practice now. The combination of details makes this section uniquely Roger and deepens our sense of who he is.

In my career I intend to apply my passion for human connection and community to providing high-quality dermatologic care and research to communities which have traditionally had difficulty accessing care. Training at your program would enable me to meet these goals and effectively treat and advocate for these patients.

Roger keeps it short, perhaps due to word count. Still, his first line clearly articulates who he is and what draws him to dermatology. Placing this line at the end of the anecdotes and examples Roger used throughout the essay helps the image of him crystallize in the minds of the selection committee. Roger’s last line isn’t our favorite—it’s a little bit common. But the rest of the essay is specific enough that we aren’t hung up on it.

Final thoughts

By reflecting on how your personal attributes and interests inform who you are and who you might be in your chosen specialty, your well-crafted, authentic, and unique personal statement will help you land those coveted residency interviews and, ultimately, match into the residency program of your dreams.

ERAS allows me to use up to 28,000 characters. Do I really need to stick to one page?

Yes. A page is considered standard, and even if you submit more, many program directors may not read past your first page. Thus, keep your statement short and sweet. Remember that one page in ERAS is 3,500 characters including spaces, which equals approximately 550–750 words.

Can I edit my personal statement after uploading it to ERAS?

Yes, ERAS allows you to edit your personal statement at any time during the application season, even if you’ve already assigned it to programs you’re applying to.

Should I address red flags in my personal statement?

It depends on the severity of the red flag. We don’t recommend using your personal statement to explain a situation that’s simply less than ideal, such as a low but passing Step 1 score. However, if you have a serious issue in your candidacy—for instance, you failed the USMLE, you repeated a preclinical year or clerkship, or you have unexplained interruptions in your medical education or career—it’s generally advisable to address it head on in order to demonstrate maturity and honesty. Don’t make excuses; do take ownership of the problem and explain how you’ve learned and grown from your mistakes.

If there is a legal issue in your past, the ERAS application contains legal disclosure fields in which you can discuss the incident. It’s typically not necessary to also address the issue in your personal statement unless it played a formative role in your journey towards your specialty.

The above are our general recommendations; however, given the many nuances and gray areas that tend to accompany red flags, it’s usually a good idea to discuss how to handle them with a trusted advisor in your specialty.

Should I tailor my personal statement to specific residency programs?

Generally speaking, it’s not necessary to tailor your personal statement to each program to which you apply. That said, ERAS does allow you to upload as many personal statements as you wish, so it is possible to send different versions of your personal statement to different programs.

Before you consider doing so, keep in mind that it’s probably not realistic to send a customized personal statement to every program that you’re applying to. Instead, you might do so for, say, your top three programs. Another approach could involve creating two different versions of your personal statement to send out as you choose.

For instance, you might have one version geared towards research-heavy programs and one geared towards community-oriented programs. Or, perhaps a few programs on your list are in your home city and the rest are located elsewhere. You could then create a personal statement for the hometown programs that includes a few sentences reflecting your geographical tie and why it’s important to your medical career (e.g. “ Having grown up in a medically underserved community in Romulus, my lifelong goal has been to improve access to healthcare for the citizens of Wayne County …”).

In any case, you should only tailor your personal statement to reflect genuine, well-founded reasons for your interest in a program. Because tailored personal statements are neither the norm nor the expectation, half-baked attempts to demonstrate fit will be noticeable.

(Note: We should mention that the one situation that always calls for multiple personal statements is if you’re applying to more than one specialty.)

Personal Statement

Writing your personal statement for the AMCAS or AACOMAS application can be daunting. Although most students focus mainly on GPA and MCAT scores, the personal statement is a very important component of your application and should be carefully written. This is your opportunity to highlight things about you that are not mentioned in other sections of your application and to distinguish yourself from other applicants.

The AMCAS essay is limited to 5300 characters (~1 page).  If you are applying for a dual-degree program (e.g., MD/PHD), you will be required to submit additional essays: the MD/PhD essay (3000 characters) and the Significant Research Experience essay (10000 characters).  The AACOMAS essay is limited to 5300 characters as well.  If you are applying to both M.D. and D.O. programs, you can use the same personal statement for both.  However, be mindful of any specific M.D. or D.O. wording that you may have used and remember that D.O. programs usually want to know why you are interested in osteopathic medicine specifically.

You should have several different people objectively read your personal statement and provide constructive feedback. Your letter writers are often a great option. There are also resources on campus that can assist you, such as the Career Center and the UGA Writing Center .  Consider the feedback you get carefully, but be sure that the personal statement is still written in your voice.

The Pre-Professional Advising Office offers a personal statement workshop during spring semesters.  While this intensive workshop is typically capped at 40 students, you can find all of the information presented here .

When should I start writing?

You need to begin working on your personal statement early in the spring semester prior to application.  Remember that the people who are helping you with your statement will need time to review it and you will need time to work through multiple drafts.  In addition, some of your letter writers will want to see a copy of your personal statement before they write your letter, so you should strive to have a competent draft on hand by March or April.

What should be included?

Some questions you may want to consider while writing this essay are:

• Why have you selected the field of medicine?
• What motivates you to learn more about medicine?
• How have you demonstrated your interest and commitment to your decision?
• What experiences have allowed you to develop the skills necessary to be successful in medical school and to become an effective physician?
• Did you have any exposure to role models who influenced your decision? Which of their attributes inspired you?
• Are your perceptions of the medical profession realistic?
• What are your professional goals?
• Is there anything you wish for medical schools to know about you that hasn't been disclosed in other sections of the application?

In addition, you may wish to include information such as:

• Unique hardships, challenges, or obstacles that may have influenced your educational pursuits.
• Commentary on significant fluctuations in your academic record that are not explained elsewhere in your application.

What should NOT be included?

• Avoid cliches : How many times do you think admissions committees have read the phrase, “I want to become a physician because I like science and I want to help people”?
• Avoid being vague : "[Insert experience] was challenging and rewarding." What does that mean? Be specific about what was impactful and how it affected you.
• Avoid brash decision-making :  Your decision to become a doctor should be the result of a series of thoughtful, conscious, and reflective decisions. NOT an instantaneous realization. Similarly, you have not “always known” that you want to be a physician. No one is "born to be a doctor." Nothing is innate, you have to work for it.
• Avoid excuses :  In general, there are better uses for your personal statement than explaining away and justifying poor grades, incidents of misconduct, etc.  However, if you choose to address these subjects, be sure to focus on what you have learned from those incidents and how your experiences have made you a stronger person.  Never, ever blame anyone else for your mistakes.
• Avoid restating resume :  Choose ONE or TWO significant and distinguishing experiences to elaborate upon.
• Avoid grandiosity :  Claiming that you plan to cure cancer (or HIV, or healthcare disparities, or anything else) shows a grave lack of understanding of whatever problem you are planning to solve. Similarly, avoid “I know what it is like to be a physician from [shadowing/clinical volunteer experience].”  No, you do not.  That is precisely why you are hoping to go to medical school.
• Avoid inflammatory or controversial topics :  You do not know the values, beliefs, and background of the person who is reading your essay.  For these reasons, you are advised to avoid making any strong statements regarding politics, religion, and other polarizing topics.  Be extremely cautious to avoid expressing any views that could be construed as derogatory to any group.  Additionally, your beliefs are not the only “correct” beliefs. 
• Do not lie :  Honesty and ethical behavior are the hallmarks of being a physician. Do not include details that you are not prepared to talk about or that are simply untrue.

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How to write a personal statement

If you want to give current article to your teenage child you might be right. But adults can be interested in it too. Personal statement is a piece of individual writing a person usually encloses to his or her university application. It's never too late to study, universities accept not only young and enthusiastic people but representatives of all ages. Anyway, we think it's vital to know how to write a personal statement. Who knows maybe next year you'll express desire to go back to school! Internet as usual can offer you a huge amount of personal statement examples for any case. We prefer to stick to theory that it should be unique and reflect best traits of your character and has a full story of your achievements. Personal statement format is not strict but of course there is a plan to follow. First is introduction. It should be catchy and captivate reader's attention from first sentence. In several blocks tell briefly but vividly about your education, experience and skills. Don't ask anyone for help, use your own words and phrases, let the committee know what a person you are. Search for tips on how to write a personal statement but do writing part yourself, without appropriating anyone's thoughts. In personal financial statement explain need of scholarship or financial aid. In personal mission statement define your primary goals you plan to achieve in life with help of high school.

Personal statement examples for different aims

Not to get lost under flood of information about personal statements, everyone should know that for each type of high school there should be a unique piece of paper.

Personal statement for graduate school won't contain any information about your desperate need of financial assistance in studying. This is what a personal financial statement for.

Planning to become a famous doctor and getting a medical certificate? Write a medical school personal statement, describe your preference. There is surely a noble reason for choosing career of doctor. After finishing studies and applying for a place in hospital as an intern there is a necessity to write residency personal statement. And again you say what made you think this very hospital would provide the best experience for you.

Dreaming of a career in jurisprudence? Be sure to make best law school personal statement ever. The competition between applicants is quite hard, as there are plenty of them. With moderate or low grades knowledge of how to write a personal statement is not just important, it's vital. When looking through samples ignore those that don't belong to necessary sphere. Medical school personal statement examples are not proper when applying for law school.

Importance of a good statement

Use of correct personal statement format is significant. Grades matter too but a brilliant piece of writing may win you a place in high school. Devote as much time as possible to compose it. Even when making a personal statement for college do your best. Examine your work several times, make notes, change part you don't like, give it to you teacher or senior to evaluate. Personal mission statement examples will help to make a right decision and sometimes completely change your mind.

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Enforcement Guidance on Harassment in the Workplace

SUBJECT: Enforcement Guidance on Harassment in the Workplace

PURPOSE: This transmittal issues the Commission’s guidance on harassment in the workplace under EEOC-enforced laws. It communicates the Commission’s position on important legal issues.

EFFECTIVE DATE: Upon issuance.

EXPIRATION DATE: This Notice will remain in effect until rescinded or superseded.

OBSOLETE DATA: This Enforcement Guidance supersedes Compliance Manual Section 615: Harassment (1987); Policy Guidance on Current Issues of Sexual Harassment (1990); Policy Guidance on Employer Liability under Title VII for Sexual Favoritism (1990); Enforcement Guidance on Harris v. Forklift Sys., Inc. (1994); and Enforcement Guidance on Vicarious Employer Liability for Unlawful Harassment by Supervisors (1999).

ORIGINATOR: Office of Legal Counsel

_______________________________

Charlotte A. Burrows Chair

TABLE OF CONTENTS

I. Introduction

A. background, b. structure of this guidance, ii. covered bases and causation, a. covered bases, 3. national origin, 4. religion, a. harassing conduct of a sexualized nature or otherwise based on sex.

b. Pregnancy, Childbirth, or Related Medical Conditions Under Title VII

c. Sexual Orientation and Gender Identity

7. Disability

8. Genetic Information

9. Retaliation

10. cross-bases issues, b. establishing causation, 1. generally.

2. Facially Discriminatory Conduct

3. Stereotyping

5. link between conduct that is not explicitly connected to a protected basis and facially discriminatory conduct, 7. comparative evidence, 8. causation issues related to sex-based harassment, iii. harassment resulting in discrimination with respect to a term, condition, or privilege of employment, a. background: distinguishing an explicit change to the terms, conditions, or privileges of employment from a hostile work environment, b. hostile work environment, 1. unwelcomeness, a. conduct that is subjectively and objectively hostile is also necessarily unwelcome, b. derivation of unwelcomeness inquiry, 2. subjectively hostile work environment, 3. objectively hostile work environment, a. in general, b. severity.

      i. In General

      ii. Hostile Work Environment Based on a Single Incident of Harassment

c. Pervasiveness

C. the scope of hostile work environment claims, 1. conduct must be sufficiently related, 2. types of conduct, a. conduct that is not directed at the complainant, b. conduct that occurs in work-related context outside of regular place of work, c. conduct that occurs in a non-work-related context, but with impact on the workplace, iv. liability, a. overview of liability standards in harassment cases, b. liability standard for a hostile work environment depends on the role of the harasser, 1. proxy or alter ego of the employer, 2. supervisor, 3. non-supervisory employees, coworkers, and non-employees, c. applying the appropriate standard of liability in a hostile work environment case, 1. alter ego or proxy - automatic liability, 2. supervisor - vicarious liability, a. hostile work environment includes a tangible employment action: no employer defense, b. hostile work environment without a tangible employment action: establishing the faragher-ellerth affirmative defense.

      i. First Prong of the Affirmative Defense: Employer’s Duty of Reasonable Care

      ii. Second Prong of the Affirmative Defense: Employee’s Failure to Take Advantage of Preventive or Corrective Opportunities

           a) Reasonable Delay in Complaining or in Failing to Use the Employer’s Complaint Procedure

           b) Reasonable Efforts to Avoid Harm Other than by Using the Employer’s Complaint Process

3. Non-Supervisory Employees (E.g., Coworkers) and Non-Employees—Negligence

a. Unreasonable Failure to Prevent Unlawful Harassment

B. unreasonable failure to correct harassment of which the employer had notice.

     i. Notice

     ii. Reasonable Corrective Action

           a) Prompt and Adequate Investigation

           b) Appropriate Corrective Action

           c) Assessing the Liability of Joint Employers

V. Systemic Harassment

A. harassment affecting multiple complainants, b. pattern or practice of harassment, vi. selected eeoc harassment resources.

Addendum on Responses to Major Comments

In 1986, the U.S. Supreme Court held in the landmark case of Meritor Savings Bank, FSB v. Vinson [1] that workplace harassment can constitute unlawful discrimination under Title VII of the Civil Rights Act of 1964 (Title VII). Decades later, harassing conduct remains a serious workplace problem. For the five fiscal years (FY) ending with FY 2023, over one-third of the charges of employment discrimination received by the Equal Employment Opportunity Commission (“the Commission” or “the EEOC”) included an allegation of unlawful harassment based on race, sex, disability, or another statutorily protected characteristic. [2] The actual cases behind these numbers reveal that many people experience harassing conduct at work that may be unlawful. 3

This Commission-approved enforcement guidance presents a legal analysis of standards for harassment and employer liability applicable to claims of harassment under the equal employment opportunity (EEO) statutes enforced by the Commission, which prohibit work-related harassment based on race, color, religion, sex (including pregnancy, childbirth, or related medical conditions; sexual orientation; and gender identity), national origin, disability, genetic information, and age (40 or over). [4] This guidance also consolidates and supersedes several earlier EEOC guidance documents: Compliance Manual Section 615: Harassment (1987); Policy Guidance on Current Issues of Sexual Harassment (1990); Policy Guidance on Employer Liability under Title VII for Sexual Favoritism (1990); Enforcement Guidance on Harris v. Forklift Sys., Inc. (1994); and Enforcement Guidance on Vicarious Employer Liability for Unlawful Harassment by Supervisors (1999).

This guidance serves as a resource for employers, employees, and practitioners; for EEOC staff and the staff of other agencies that investigate, adjudicate, or litigate harassment claims or conduct outreach on the topic of workplace harassment; and for courts deciding harassment issues. This document is not intended to be a survey of all legal principles that might be appropriate in a particular case. 5 The contents of this document do not have the force and effect of law, are not meant to bind the public in any way, 6 and do not obviate the need for the EEOC and its staff to consider the facts of each case and applicable legal principles when exercising their enforcement discretion. Nothing in this document should be understood to prejudge the outcome of a specific set of facts presented in a charge filed with the EEOC. In some cases, the application of the EEO statutes enforced by the EEOC may implicate other rights or requirements including those under the United States Constitution; other federal laws, such as the Religious Freedom Restoration Act (RFRA); or sections 702(a) and 703(e)(2) of Title VII. 7 The EEOC will consider the implication of such rights and requirements on a case-by-case basis.

In explaining how to evaluate whether harassment violates federal EEO law, this enforcement guidance focuses on the three components of a harassment claim. Each of these must be satisfied for harassment to be unlawful under federal EEO laws.

• Covered Bases and Causation : Was the harassing conduct based on the individual’s legally protected characteristic under the federal EEO statutes?
• Discrimination with Respect to a Term, Condition, or Privilege of Employment : Did the harassing conduct constitute or result in discrimination with respect to a term, condition, or privilege of employment ?
• Liability : Is there a basis for holding the employer liable for the conduct?

This guidance also addresses systemic harassment and provides links to other EEOC harassment-related resources. 8

Harassment must be based on an employee’s legally protected characteristic.

 Under the first part of a harassment claim, harassment (or harassing conduct) is only covered by federal EEO laws if it is based on one (or more) of the individual’s characteristics that are protected by these laws. In this document, the terms “harassment” and “harassing conduct” are generally used interchangeably. The terms refer to conduct that can, but does not necessarily always, constitute or contribute to unlawful harassment, including a hostile work environment. Not all harassing conduct violates the law, even if it is because of a legally protected characteristic. As discussed throughout this guidance, whether specific harassing conduct violates the law must be assessed on a case-by-case basis.

Section II.A of this guidance identifies the legally protected characteristics covered by the federal EEO laws enforced by the EEOC.

Section II.B of this guidance explains how to determine whether harassing conduct is because of a legally protected characteristic.

Taken together, these two sections address whether conduct is based on a protected characteristic and, therefore, whether it can contribute to creating a hostile work environment. S ection II does not address whether such conduct reaches the point of creating a hostile work environment. The next section of this guidance, section III , discusses how to determine whether harassing conduct rises to the level of a hostile work environment.

Title VII prohibits discrimination, including unlawful harassment, based on race. Harassment is based on a complainant’s race if it is because the complainant is Black, Asian, White, multiracial, or another race. Examples of harassing conduct based on race include racial epithets or offensive comments about members of a particular race, or harassment based on stereotypes about the complainant’s race. [9] It also can include harassment based on traits or characteristics linked to an individual’s race, such as the complainant’s name, cultural dress, accent or manner of speech, and physical characteristics, including appearance standards (e.g., harassment based on hair textures and hairstyles commonly associated with specific racial groups). [10]

Example 1: Race-Based Harassment. Mia, a personal trainer at a large fitness center chain, is multiracial (Asian, Black, and Pacific Islander). Some coworkers refer to Mia using epithets directed at her mixed-race status, including “mutt.” These coworkers also call Mia slurs based on her separate racial attributes. Other coworkers make comments that they don’t consider to be insulting, [11] such as telling Mia how “exotic” she looks; calling her “cute nicknames,” such as “panda” and “Moana”; and commenting that Mia inherited the “best traits,” such as being strong because she is part Pacific Islander, athletic because she is part Black, and smart and articulate because she is part Asian. Based on these facts, the coworkers’ harassing conduct toward Mia is based on race.

Example 2: Race-Based Harassment. Chelsea, a hostess at an upscale restaurant, is a Black woman who wears her hair in locs for both cultural reasons and to reflect the natural texture of her hair. Chelsea’s manager, Gregor, periodically tries to touch Chelsea’s hair while asking questions about it, such as “why does Black people’s hair look like that?” and “what does it feel like?” Gregor says that Chelsea could go from “savage to stunning” if she relaxed her hair. On other occasions, Gregor criticizes her hair as “messy,” “untamed,” and “unprofessional.” Based on these facts, Gregor’s harassing conduct toward Chelsea is based on her race.

Although sometimes related to harassment based on race or national origin, color-based harassment due to an individual’s pigmentation, complexion, or skin shade or tone is independently covered by Title VII. 12 For example, if a supervisor harasses Black employees with darker complexions but does not harass Black employees with lighter skin tones, this may be evidence that the harassment was due to color.

Example 3: Color-Based Harassment. Shawn, an inspector at a medical equipment manufacturing facility, is a Pakistani-American with brown skin. Two of Shawn’s supervisors make comments to him that suggest his skin is the color of human feces. Based on these facts, the supervisors’ harassing conduct toward Shawn is based on his color. 13

Title VII prohibits employment discrimination, including unlawful harassment, based on national origin—meaning discrimination due to a complainant’s, or the complainant’s ancestors’, place of origin. Harassment based on national origin includes ethnic epithets, derogatory comments about individuals of a particular nationality, and use of stereotypes about the complainant’s national origin. 14 It also can include harassment regarding traits or characteristics linked to an individual’s national origin, such as physical characteristics, ancestry, or ethnic or cultural characteristics (e.g., attire or diet), and linguistic characteristics (e.g., non-English language accent or a lack of fluency in English). 15

Example 4: Harassment Based on National Origin. Antonio is an immigrant from Mexico who works at a butcher shop. Over the course of several months, his Mexican-American and White managers subject him to slurs about his Mexican origin such as “wetback” and other vulgar and derogatory epithets in Spanish. They also mock and ridicule Antonio’s accent and limited English proficiency. Based on these facts, the managers’ harassing conduct toward Antonio is based on his national origin.

Title VII prohibits employment discrimination, including unlawful harassment, based on religion. Religion is broadly defined under Title VII. [16] Harassment based on religion includes the use of religious epithets or offensive comments based on a complainant’s religion (including atheism or lack of religious belief [17] ), religious practices, or religious dress. 18 It also includes harassment based on religious stereotypes [19] and harassment because of a request for a religious accommodation or receipt of a religious accommodation. [20]

Example 5: 21 Religion-Based Harassment. Thiago, a fraud investigator at a property and casualty insurer, is agnostic and rejects organized religion. After Thiago’s sister died unexpectedly, Thiago is despondent. He is approached by a coworker, Laney, who says that she can communicate with the dead and has received the following messages from Thiago’s sister: the sister is suffering in Hell, and Thiago will go to Hell as well if he does not “find God.” Thiago becomes upset and asks Laney to never bring up the topic again. Nevertheless, Laney repeatedly encourages Thiago to find religion so Thiago will not “go to Hell like his sister,” despite Thiago’s ongoing requests for Laney to “drop it.” Based on these facts, Laney’s harassing conduct toward Thiago is based on religion. 22

Example 6: Harassment Based on Religious Accommodation. Harpreet is an observant Sikh who, because of his religious beliefs, does not cut his beard. He works as an emergency medical technician (EMT) for an ambulance services provider. Harpreet’s employer has a policy that requires all EMTs to be able to wear a tight-fitting respirator, which requires a clean-shaven face where the respirator touches the skin. When Harpreet’s employer learns that he cannot meet the respirator requirement due to his beard, the employer grants Harpreet a religious accommodation by permitting Harpreet to use a loose-fitting powered air purifying respirator (PAPR) instead of a tight-fitting respirator. Harpreet’s supervisor, Jessie, has expressed disdain for Harpreet’s accommodation, including by telling colleagues that PAPRs scare patients and saying, “Anybody who can’t wear a basic respirator shouldn’t be working here.” Jessie also refers to Harpreet as “looking unprofessional” or “shabby.” Based on these facts, Jessie’s harassing conduct is targeted at Harpreet’s religious accommodation and therefore is based on Harpreet’s religion.

Religious harassment also encompasses explicitly or implicitly coercing employees to engage in religious practices at work. 23

Example 7: Harassment Based on Religious Coercion. Sandra, an exterminator for a pest control service, is a Christian. The owner of the pest control service, Fabian, is a self-described “spiritual guru” who believes he is called by the universe to help people transcend the Judeo-Christian belief system. Fabian regularly makes comments to Sandra denigrating Judeo-Christian tenets; asks Sandra probing questions about her faith; distributes tracts arguing that “traditional religion” is the cause of all ills in modern society; and states a “strong hope” that Sandra will attend his lunchtime lectures, which consistently focus on Fabian’s religious beliefs. While Fabian claims he would never require employees to share his beliefs, attend his lectures, or read the material he distributes, he also keeps track of which employees do and do not participate in his religious activities and tends to act with favoritism toward employees who agree with or are receptive to his religious messages. Sandra feels she must feign interest in Fabian’s beliefs or else she will be subject to ostracism or possibly even termination. Based on these facts, Fabian’s harassing conduct toward Sandra is based on religion. 24

Title VII prohibits employment discrimination, including unlawful harassment based on sex. Under Title VII, “sex” includes “pregnancy, childbirth, and related medical conditions” and sexual orientation and gender identity, as discussed in this section.

Harassing conduct based on sex includes conduct of a sexualized nature, such as unwanted conduct expressing sexual attraction or involving sexual activity (e.g., “sexual conduct”); sexual attention or sexual coercion, such as demands or pressure for sexual favors; rape, sexual assault, or other acts of sexual violence; or discussing or displaying visual depictions of sex acts or sexual remarks. 25

Harassment based on sex under Title VII 26 also includes non-sexual conduct based on sex, 27 such as sex-based epithets; sexist comments (such as remarks that women do not belong in management or that men do not belong in the nursing profession); or facially sex-neutral offensive conduct motivated by sex (such as bullying directed toward employees of one sex). 28

Example 8: Sex-Based Harassment. John, an employee in a supermarket bakery department, works with a coworker, Laverne, who rubs up against him in a sexual manner, tells sexual jokes, and displays dolls made from dough in sexual positions. Based on these facts, Laverne’s harassing conduct toward John is based on his sex.

Example 9: Sex-Based Harassment. Aiko, a construction worker on a road crew, is subjected to sex-based epithets and other demeaning sex-based language by her supervisor, such as “sandwich-maker” and “baby.” This supervisor also disparages women’s participation in the construction industry, for example by stating that road construction is “a man’s job.” Based on these facts, the supervisor’s harassing conduct toward Aiko is based on sex.

Example 10: Sex-Based Harassment. Ferguson, a millwright at a cabinet manufacturer, has just returned from a short period of medical leave taken to recover from a vasectomy. Immediately upon his return, some of Ferguson’s coworkers repeatedly ridicule Ferguson for the vasectomy, calling him “gelding,” “eunuch,” and “numb nuts,” and saying things such as “why did you neuter yourself like a dog?” and “a real man would never get a vasectomy.” Based on these facts, the coworkers’ harassing conduct toward Ferguson is based on sex.

b. Pregnancy, Childbirth, or Related Medical Conditions Under Title VII [29]

Sex-based harassment under Title VII includes harassment based on pregnancy, [30] childbirth, or related medical conditions. 31 This can include issues such as lactation; [32] using or not using contraception; [33] or deciding to have, or not to have, an abortion. [34] Harassment based on these issues generally would be covered if it is linked to a targeted individual’s sex including pregnancy, childbirth, or related medical conditions.

Example 11: Pregnancy-Based Harassment. Kendall, a veterinary assistant at a nationwide veterinary clinic chain, recently announced to coworkers that she is pregnant. After Kendall’s announcement, one of her supervisors, Veronica, begins berating Kendall’s work as slow, shoddy, and scatter-brained, and accuses Kendall of focusing more on getting ready for her new baby than doing her job. Veronica also begins to scrutinize Kendall’s bathroom usage and, on at least one occasion, yelled at Kendall for “always” being in the bathroom. As Kendall’s pregnancy progresses, Veronica refers to Kendall as a “heifer,” and makes the comment, “We don’t treat livestock at this office.” Based on these facts, Veronica’s harassing conduct toward Kendall is based on sex (pregnancy).

Example 12: Harassment Based on Pregnancy-Related Medical Condition (Lactation). Lisbet, a software engineer for a video game publisher, recently returned to work after giving birth. Lisbet uses a lactation room at work as needed in order to express breastmilk. Lisbet’s coworker, Nathaniel, knocks loudly on the lactation room door while Lisbet is inside and pretends that he is going to enter. Nathaniel also refers to Lisbet’s breasts as “milk jugs,” makes suckling noises when Lisbet enters and exits the lactation room, and asks Lisbet if he can have a squirt of milk for his coffee. 35 Nathaniel also refers to the lactation room as “Lisbet’s getaway” and asks why he is not allowed to take breaks in private rooms. Based on these facts, Nathaniel’s harassing conduct toward Lisbet is based on a pregnancy-related medical condition (lactation).

Example 13: Harassment Based on Pregnancy-Related Medical Condition (Morning Sickness). Kristina, a graphic designer at a marketing firm, is experiencing pregnancy-related morning sickness. Kristina’s employer accommodates her limitations due to morning sickness by permitting Kristina to telework up to three days per week and utilize flexible scheduling on the days she comes into the office. Kristina’s colleagues complain that pregnant women always get special perks and privileges and accuse Kristina of getting pregnant “just so she can kick back, relax at home on the couch, and collect a paycheck.” During a team meeting to discuss staffing a new, high-priority portfolio, when Kristina requests to be considered, her coworkers scoff that “if Kristina is so sick that she cannot come into the office, how can she be well enough to work on such an important account?” Based on these facts, the coworkers’ harassing conduct toward Kristina is based on a pregnancy-related medical condition (morning sickness).

Sex-based discrimination under Title VII includes employment discrimination based on sexual orientation or gender identity. 36 Accordingly, sex-based harassment includes harassment based on sexual orientation or gender identity, including how that identity is expressed. 37 Harassing conduct based on sexual orientation or gender identity includes epithets regarding sexual orientation or gender identity; 38 physical assault due to sexual orientation or gender identity; 39 outing (disclosure of an individual’s sexual orientation or gender identity without permission); 40 harassing conduct because an individual does not present in a manner that would stereotypically be associated with that person’s sex; 41 repeated and intentional use of a name or pronoun inconsistent with the individual’s known gender identity (misgendering); [42] or the denial of access to a bathroom or other sex-segregated facility consistent with the individual’s gender identity. 43

Example 14: Harassment Based on Sexual Orientation. Heidi, a staff journalist at a media conglomerate, recently attended a company award ceremony with her wife, Naomi. After the ceremony, one of Heidi’s coworkers, Trevor, approaches Heidi and says, “I did not know you were a d*ke, that’s so hot.” Trevor asks Heidi questions such as, “because you are both girly-girls, who is the man in your marriage?” and “who wears the pants at home?” 44 Trevor also repeatedly sends the scissor emoji and images of scissors to Heidi, which Trevor intends as a euphemism for Heidi having sex with her wife. Based on these facts, Trevor’s harassing conduct toward Heidi is based on her sexual orientation.

Example 15: Harassment Based on Gender Identity. Chloe, a purchase order coordinator at a retail store warehouse, is approached by her supervisor, Alton, who asks whether she was “born a man” because he had heard a rumor that “there was a transvestite in the department.” Chloe disclosed to Alton that she is transgender and asked him to keep this information confidential. After this conversation, Alton instructed Chloe to wear pants to work because a dress would be “inappropriate,” despite other purchase order coordinators being permitted to wear dresses and skirts. Alton also asks inappropriate questions about Chloe’s anatomy and sexual relationships. Further, whenever Alton is frustrated with Chloe, he misgenders her by using, with emphasis, “he/him” pronouns, sometimes in front of Chloe’s coworkers. Based on these facts, Alton’s harassing conduct toward Chloe is based on her gender identity. 45

The Age Discrimination in Employment Act (ADEA) 46 prohibits age-based discrimination, including unlawful harassment, of employees forty or older because of their age. 47 This includes harassment based on negative perceptions about older workers. 48 It also includes harassment based on stereotypes about older workers, even if they are not motivated by animus, such as pressuring an older employee to transfer to a job that is less technology-focused because of the perception that older workers are not well-suited to such work or encouraging an older employee to retire. 49

Example 16: Age-Based Harassment. Lulu, age sixty-eight, is a makeup artist and salesperson at a department store. Lulu’s manager repeatedly asks Lulu about her retirement plans, despite Lulu expressing that she has no interest in retiring. Lulu’s manager also tells her that the brand needs “fresh faces” and “high energy.” When Lulu makes even a minor mistake, her manager disparages Lulu for having “senior moments.” Further, on one occasion, the manager snapped at Lulu, “Nobody wants makeup advice from their granny.” Based on these facts, the manager’s harassing conduct toward Lulu is based on her age.

7. Disability 50

Title I of the Americans with Disabilities Act (ADA) 51 prohibits employment discrimination, including unlawful harassment, based on an individual’s physical or mental disability, [52] including harassment based on stereotypes about individuals with disabilities in general or about an individual’s particular disability. It also can include harassment based on traits or characteristics linked to an individual’s disability, such as how an individual speaks, looks, or moves. [53]

Example 17: Disability-Based Harassment. Abdul, a financial advisor at a private wealth management firm, has a pronounced stutter resulting from anxiety. Abdul’s coworkers mockingly imitate his stutter 54 and ask Abdul to repeat himself, even though the coworkers understood what Abdul said. Based on these facts, the coworkers’ harassing conduct toward Abdul is based on disability.

Disability-based harassment also includes:

Harassment because of an individual’s request for, or receipt of, reasonable accommodation; [55]

Example 18: Harassment Based on Disability Accommodation. Charlie, a seasonal cashier at a garden supply store, has psoriatic arthritis, which affects his knees and ankles and makes standing for prolonged periods of time painful. Charlie’s employer has a rule that prohibits cashiers from using fatigue standing mats or chairs while at the cash register, but grants Charlie a reasonable accommodation under the ADA to use a mat or chair as needed. Charlie’s coworkers berate him for getting “special treatment.” They also hide Charlie’s mat and chair, which prevents Charlie from starting his work on time, because it’s “unfair” that he gets to be “more comfortable” than them. Based on these facts, the coworkers’ harassing conduct toward Charlie is based on disability (receipt of a reasonable accommodation).

• harassment because an individual is regarded as having an impairment, even if the individual does not have an actual disability, or a record of disability, under the ADA; 56
• harassment because an individual has a record of a disability, even if the individual currently does not have a disability; 57 and

harassment based on the disability of an individual with whom they are associated. 58

Example 19: Harassment Based on Disability of Person with Whom the Employee Is Associated. Karl’s husband, Jamal, has long COVID that meets the ADA’s definition of disability. Karl’s employer, a business consulting firm, has a policy that allows employees to telework three days each week. One of Karl’s coworkers, Lenny, posts a statement on the shared team communication platform that reads in part, “Keep Karl Home Every Day! If Karl’s husband is so sick, then Karl needs to stay at home, otherwise he is going to infect us all!” Karl periodically uses his accrued paid time off to take Jamal to doctor’s appointments, which often coincide with team meetings. Sometimes during these meetings, a different coworker, Barry, questions Karl’s professional competence and dedication given his recent focus on taking care of Jamal, stating that Karl seems more interested in helping Jamal “get over a cold” than doing his job. Based on these facts, Lenny’s and Barry’s harassing conduct toward Karl is based on disability (association with a person with a disability).

8. Genetic Information 59

The Genetic Information Nondiscrimination Act (GINA) 60 prohibits employment discrimination, including unlawful harassment, on the basis of genetic information, which includes harassment based on an individual’s, or an individual’s family member’s, genetic test or on the basis of an individual’s family medical history. 61 For example, harassment based on genetic information includes harassing an employee because the employee carries the BRCA gene, which is linked to an increased risk of breast and ovarian cancer, or because the employee’s mother recently experienced a severe case of norovirus, which resulted in overnight hospitalization. 62

Example 20: Harassment Based on Genetic Information. Manuella, a web developer at a university, joined in on a lively conversation between coworkers who recently used DNA ancestry testing to learn more about their extended families. Some mentioned finding unknown cousins, and others said that they had extended family from countries that surprised them. Manuella, taking part in the conversation, mentioned that although she had not taken a DNA ancestry test, a cousin recently took a genetic test that revealed that they had inherited the gene mutation that would put them at a higher risk of developing Hypertrichosis, a condition also known as Werewolf Syndrome. Soon after this discussion, coworkers began to refer to Manuella as “the werewoman,” to make howling noises when they passed her office, and to leave dog treats on her desk. Based on these facts, the coworkers’ harassing conduct toward Manuella is based on her genetic information.

The EEO statutes prohibit employers from retaliating against employees and applicants for employment because of their “protected activity”—opposing an employer’s unlawful discrimination under the EEO statutes or participating in an investigation, hearing, or proceeding under the EEO statutes. 63

Sometimes, retaliatory conduct is characterized as “retaliatory harassment.” The threshold for establishing unlawful retaliatory harassment is different than that for a discriminatory hostile work environment. As the Supreme Court explained in Burlington Northern & Santa Fe Railway Co. v. White , the EEO laws’ antiretaliation provisions complement their antidiscrimination provisions but protect against a broader range of behaviors—they forbid anything that might deter a reasonable person from engaging in protected activity. [64] Thus, retaliatory harassing conduct can be challenged under the Burlington Northern standard even if it is not sufficiently severe or pervasive to alter the terms and conditions of employment by creating a hostile work environment. [65]

If an employee has been subjected both to harassment based on race, sex, or another protected characteristic and to retaliation, then the legal standard or standards that apply to particular harassing conduct will depend on whether the conduct is being challenged as part of a harassment claim, a retaliation claim, or both.

For a more detailed discussion of retaliation, see EEOC, Enforcement Guidance on Retaliation and Related Issues (2016), https://www.eeoc.gov/laws/guidance/enforcement-guidance-retaliation-and-related-issues .

Discussed below are some issues that apply to all of the covered bases.

Harassment based on the perception that an individual has a particular protected characteristic—for example, the belief that a person has a particular national origin, religion, or sexual orientation—is covered by federal EEO law even if the perception is incorrect. [66] Thus, harassment of a Hispanic person because the harasser believes the individual is Pakistani is national origin-based harassment, and harassment of a Sikh man wearing a turban because the harasser thinks he is Muslim is religious harassment, even if the perception in both instances is incorrect.

The EEO laws also cover “associational discrimination.” This includes harassment because the complainant associates with someone in a different protected class 67 or harassment because the complainant associates with someone in the same protected class. 68 For example, the EEO laws apply to harassment of a White employee because his spouse is Black 69 or harassment of a Black employee because she has a biracial child. 70 Although the association often involves a close relationship, such as with a close relative or friend, the degree of closeness is irrelevant to whether the association is covered. [71]

Harassment that is based on the complainant’s protected characteristic is covered even if the harasser is a member of the same protected class (intraclass harassment). [72]

Example 21: Intraclass Harassment Based on Age. Pedro, age sixty-five, is a salesperson at a furniture store. Pedro’s supervisor, Simon, age fifty-two, has recently become dismissive of Pedro. After Pedro asks to use some personal leave, Simon denies Pedro’s request, stating, “You old motherf**ker, you are not taking a day off.” After that, Simon stops referring to Pedro by name, and instead calls him “old man” and “pops.” 73 Simon also refers to Pedro as “over the hill.” Based on these facts, Simon’s harassing conduct toward Pedro is based on Pedro’s age even though Simon also is within the ADEA’s protected class (40 or older).

Example 22: Intraclass Harassment Based on National Origin. Mei, a flight attendant at a global airline, is of Chinese ancestry. Her supervisor, Hua, is also of Chinese ancestry. Hua frequently berates Mei for not living up to Hua’s conception of an ideal Chinese worker. For example, Hua calls Mei lazy, useless, and spoiled; says that Mei’s ancestors would be ashamed of her; and says that Mei “wouldn’t last a day in China.” Hua also says Mei should be proud to come from such an industrious and responsible culture, and that Mei “might as well be Caucasian” based on her mediocre performance. Based on these facts, Hua’s harassing conduct toward Mei is based on Mei’s national origin even though they are both of Chinese ancestry. 74

Example 23: Intraclass Harassment Based on Sex. Dara and Sloane are lab technicians at a pharmaceutical research laboratory. On multiple occasions, one of their coworkers, Rose, makes dismissive comments to Dara, who has three children, such as, “shouldn’t mothers stay at home with their kids?” and “don’t expect to move up the career ladder with all of those children.” Rose also makes dismissive comments to Sloane, who has no children and intends to remain childfree, on a handful of occasions, such as, “women who don’t want children are frigid,” “it is sad to watch you choose a career over a family,” and “are you sure you don’t want a baby? Every woman should want a baby!” Based on these facts, Rose’s harassing conduct toward Dara and Sloane is based on their sex even though they all are women.

Harassment may be based on more than one protected characteristic of an employee, either under a single EEO statute, such as Title VII, or under multiple EEO statutes, such as Title VII and the ADEA. For example, a Black woman might be harassed both because she is Black and because she is a woman, or alternatively, because she is a Black woman. This last example is sometimes referred to as intersectional harassment, or harassment based on the intersection of two or more protected characteristics, which may, in fact, compound the harm. [75] If a Black woman is harassed based on stereotypes about Black women, such harassment is covered as both race and sex discrimination. Similarly, if a woman who is age forty or older is harassed based on stereotypes about older women, this harassment is covered as both age and sex discrimination. 76

Example 24: Intersectional Harassment Based on Age and Sex. Janet, age fifty-one, works as a sales associate for a pet supplies store. One day at work, Janet quickly removed her jacket and began fanning herself. An assistant manager, Truman, stated when he observed her behavior, “Oh, you’re having a hot flash! You must be menopausal.” Truman then added, “You know your husband will start looking for younger women.” Janet covered her ears and said, “I don’t want to hear you talking about any of this.” On another occasion when Janet mixed up a customer order, Truman yelled at her and asked if the mistake was because she was having a “menopausal moment” or because she was just getting too old to get the orders right. Janet was visibly flustered by his yelling, which prompted Truman to add, “Don’t get so emotional. Isn’t there something you can take for your hormones?” Based on these facts, Truman’s harassing conduct toward Janet is based on her status as an older woman.

Harassment based on one protected characteristic, such as national origin, also may overlap with harassment based on another characteristic, such as religion, because of the close association (actual or perceived) between two protected groups. For example, harassment against an individual who is Middle Eastern and Muslim may be based on both national origin and religion. [77]

Harassment based on protected characteristics includes harassment based on social or cultural stereotypes regarding how persons of a particular protected group, such as persons of a particular race, national origin, or sex, may act, appear, or behave. [78] This includes, but is not limited to, harassment based on stereotypes about racial, ethnic, or other protected characteristics, or sex-based stereotypes about family responsibilities, [79] suitability for leadership, [80] or gender roles. 81

Example 25: Harassment Based on Stereotype About Race. Sydney, who is Black, is a sales associate at a jewelry store. One of Sydney’s coworkers, Mackenzie, repeatedly admonishes Sydney not to steal anything from the store. 82 Mackenzie frequently brings up news stories and social media videos depicting Black people engaging in theft, and suggests that all Black people, including Sydney, have a propensity to steal. Based on these facts, Mackenzie’s harassing conduct toward Sydney is based on race.

Example 26: Harassment Based on Stereotypes About National Origin. Mirlande, a Haitian-American, is an esthetician at a luxury resort and spa. One of Mirlande’s coworkers, Celine, believes that all Haitians practice voodoo and, based on this cultural assumption about Haitians, repeatedly makes voodoo-related remarks, such as that Mirlande will curse staff members and clients, knows a witch doctor, and has voodoo dolls at home. Based on these facts, Celine’s harassing conduct toward Mirlande is based on national origin.

As discussed below in section II.B, harassing conduct need not explicitly refer to a protected characteristic to be based on that characteristic where there is other evidence establishing causation.

Causation is established if the evidence shows that the complainant was subjected to harassment because of the complainant’s protected characteristic, whether or not the harasser explicitly refers to that characteristic or targets a particular employee. [83] If an employee experiences harassment in the workplace but the evidence does not show that the harassment was based on a protected characteristic, the EEO statutes do not apply. [84]

Example 27: Insufficient Evidence That Harassment Was Based on a Protected Characteristic. Isaiah, a customer service representative at a financial services firm, alleges he was subjected to harassment based on his national origin and color by his coworker, Zach. Isaiah asserts that last winter Zach became increasingly hostile and rude, throwing paper at Isaiah, shoving him in the hall, and threatening to physically harm him. Zach’s misconduct started shortly after a disagreement during a league basketball game during which Isaiah, captain of the firm’s basketball team, benched Zach. No evidence was found during the investigation to link Zach’s threats and harassment to Isaiah’s national origin or color; therefore, Isaiah cannot establish that Zach’s misconduct subjected him to harassment because of a protected characteristic. 85

Example 28: Sufficient Evidence That Harassment Was Based on a Protected Characteristic. Julius, who is Black, works on a line operation crew for a pharmaceutical manufacturer. All line crew members are Black, and they are supervised by Murphy, who is White. Murphy frequently refers to himself as a “zookeeper” and to the crew, including Julius, as “my animals.” Murphy does not refer to members of other line crews, which are comprised of non-Black employees, as “animals”; likewise, Murphy does not refer to supervisors of those other line crews as “zookeepers.” Following an investigation, evidence shows that Murphy calls Julius and crew members “animals” because of their race, even though Murphy does not directly refer to race. Based on these facts, Julius can establish that Murphy subjected him to harassment because of race, a protected characteristic. 86

The determination of whether hostile-work-environment harassment is based on a protected characteristic will depend on the totality of the circumstances. 87 Although causation must be evaluated based on the specific facts in a case, the principles discussed below will generally apply in determining causation. Not all principles will necessarily apply in every case.

2. Facially Discriminatory [88] Conduct

Conduct that explicitly insults or threatens an individual based on a protected characteristic—such as racial epithets or graffiti, sex-based epithets, offensive comments about an individual’s disability, or targeted physical assaults based on a protected characteristic—discriminates on that basis. [89] The motive of the individual engaging in such conduct is not relevant to whether the conduct is facially discriminatory. Such conduct also need not be directed at a particular worker based on that worker’s protected characteristic, nor must all workers with the protected characteristic be exposed to the conduct. For example, degrading workplace comments about women in general, even if they are not related to a specific female employee, show anti-female animus on their face, so no other evidence is needed to show that the comments are based on sex. [90] Further, derogatory comments about women are sex-based even if all employees are exposed to the comments. 91

Example 29: Causation Established Where Harassment Is Facially Discriminatory. Kiran, an archivist at a non-profit foundation, is an individual with a neuropathic condition that causes his muscles to atrophy and degenerate. As a result of his condition, Kiran walks with a limp and must wear leg braces. On a near-daily basis his coworkers make fun of his limp and leg braces by mimicking his gait and calling him names like “Forrest Gump” and “cr*pple.” Based on these facts, Kiran has been subjected to harassment based on disability that is facially discriminatory. 92

Harassment is based on a protected characteristic if it is based on social or cultural expectations—be they intended as positive, negative, or neutral—regarding how persons of a particular protected group may act or appear. [93] This includes harassment based on sex-based assumptions about family responsibilities, [94] suitability for leadership, [95] gender roles, 96 weight and body types, 97 the expression of sexual orientation or gender identity, 98 or being a survivor of gender-based violence. Similarly, harassment based on race includes derogatory comments involving racial stereotypes, such as referring to Black employees as drug dealers 99 or suggesting that Black employees have the propensity to commit theft. 100

Such stereotyping need not be motivated by animus or hostility toward that group. [101] For example, age-based harassment might include comments that an older employee should consider retirement so that the employee can enjoy the “golden years.” [102] Likewise, sex-based harassment might include comments that a female worker with young children should switch to a part-time schedule so that she can spend more time with her children. 103

Example 30: Causation Established Based on Sex Stereotyping. After Eric, an iron worker, made a remark that his foreman, Josh, considered “feminine,” Josh began calling Eric “Erica,” “princess,” and “f*ggot.” Several times a week, Josh approached Eric from behind and simulated intercourse with him. More than once, Josh exposed himself to Eric. Based on these facts, Josh targeted Eric based on his perception that Eric did not conform to traditional male stereotypes and subjected Eric to harassment based on sex. 104

Example 31: Causation Established Based on Sex Stereotyping. Maria, a receptionist, has recently experienced domestic violence. Because Maria must attend court dates related to the domestic violence, she discloses her situation to her supervisor, Nolan. Nolan warns Maria that she should not take “too much” leave and should not bring “drama” into the workplace because “women can be histrionic and unreliable.” Nolan also comments that “women think everything is domestic violence” and that “a good wife doesn’t have to worry about anything in her marriage.” Nolan begins to criticize Maria’s decision-making skills, stating that Maria can’t be relied on to make good choices because she can’t even manage her personal problems. Based on these facts, Nolan targeted Maria based on his sex-based perception of victims of gender-based violence and subjected Maria to harassment based on sex.

Conduct must be evaluated within the context in which it arises. 105 In some cases, the discriminatory character of conduct that is not facially discriminatory becomes clear when examined within the specific context in which the conduct takes place or within a larger social context. For example, the Supreme Court observed that use of the term “boy” to refer to a Black man may reflect racial animus depending on such factors as “context, inflection, tone of voice, local custom, and historical usage.” [106] In some contexts, terms that may not be facially discriminatory when viewed in isolation, such as “you people,” may operate as “code words” that contribute to a hostile work environment based on a protected characteristic. [107]

Example 32: Causation Established by Social Context. Ron, a Black truck driver, finds banana peels on his truck on multiple occasions. After the third of these occasions, Ron sees two White coworkers watching his reaction to the banana peels. There is no evidence that banana peels were found on any other truck or that Ron found any trash on his truck besides the banana peels. Based on these facts, the appearance of banana peels on Ron’s truck is likely not coincidental. Further, because banana peels are used to invoke “monkey imagery,” it would be reasonable to conclude, given the history of racial stereotypes against Black individuals, that the banana peels were intended as a racial insult. Therefore, the conduct under these circumstances constitutes harassment based on race. [108]

Conduct that is neutral on its face may be linked to other conduct that is facially discriminatory, such as race-based epithets or derogatory comments about individuals with disabilities. Facially neutral conduct therefore should not be separated from facially discriminatory conduct and then discounted as non-discriminatory. [109] In some instances, however, facially discriminatory conduct may not be sufficiently related to facially neutral conduct to establish that the latter also was discriminatory. [110]

Example 33: Facially Neutral Conduct Sufficiently Related to Religious Bias. Imani, a devout Christian employed as a customer service representative, alleges that coworkers made offensive comments or engaged in other hostile conduct related to her religious beliefs and practices, including suggesting that Imani belonged to a cult; calling her religious beliefs “crazy”; drawing devil horns, a devil tail, and a pitchfork on her Christmas photo; and cursing the Bible and teasing her about Bible reading. In addition, the same coworkers excluded Imani from office parties and subjected her to curse words that the coworkers knew Imani regarded as offensive because of her religion. Although some of the coworkers’ conduct was facially neutral with respect to religion, that conduct was closely related to the religious harassment and thus the entire pattern of harassment was based on Imani’s religion. [111]

If harassment began or escalated shortly after the harasser learned of the complainant’s protected status, including religion, pregnancy, sexual orientation, or gender identity, the timing may suggest that the harassment was discriminatory. [112]

Example 34: Timing as Evidence of Causation. Sami, a security guard at an electronics store, discloses his Egyptian ancestry to coworkers during a conversation about turmoil in the Middle East. Following this disclosure, Sami’s colleagues, who had made offensive comments about Middle Eastern people during the conversation, begin to avoid and ostracize him. Approximately one week after Sami disclosed his national origin, Sami arrives late for his shift, and a coworker asks, “Did your camel break down?” Another coworker begins to hum the Bangles’ “Walk Like an Egyptian” and mime the music video’s dance moves when Sami walks by. The timing of the coworkers’ conduct, in addition to the content of the conduct, provides evidence that Sami has been subjected to discrimination based on national origin.

Evidence showing qualitative and/or quantitative differences in the conduct directed against individuals in different groups can support an inference that the harassment of workers subjected to more, or more severe, harassment was based on their protected status. [113]

Example 35: Comparative Evidence Gives Rise to Inference that Harassment Is Based on a Protected Characteristic. Tyler is a manager for an educational services firm. Tyler directly supervises two women, Kailey and Anu, and two men, Sandeep and Levi. Tyler regularly hovers over Kailey and Anu as they work to make sure they don’t “mess up.” Tyler yells and shakes his fist at Kailey and Anu when he is angry at them. In addition, although Tyler is occasionally irritable, he generally engages in friendly banter with Sandeep and Levi that is different from the aggressiveness that he displays toward female employees. Tyler sometimes even allows Sandeep and Levi to relax in his office in the afternoons, doing little or no work. Tyler permits Sandeep and Levi to leave the office early on Fridays and does not monitor their work performance. Tyler’s different treatment of women and men who are similarly situated would support the conclusion that Tyler’s treatment of Kailey and Anu was based on their sex. 114

A claim of sex-based harassment may rely on any of the causation theories described in the preceding sections and in this document. The Supreme Court has addressed three non-exclusive evidentiary routes for establishing causation in a sex-based harassment claim: (1) explicit or implicit proposals of sexual activity; (2) general hostility toward members of the complainant’s sex; and (3) comparative evidence showing how the harasser treated persons who shared the complainant’s sex compared to the harasser’s treatment of those who did not. 115 As noted, these three routes are not exclusive; they are examples of ways in which it may be established that harassment is based on sex. 116 For example, harassment is sex-based if it occurs because of sex stereotyping 117 or if members of one sex are routinely sexualized.

For workplace harassment to violate the law, not only must it be based on a protected characteristic, as discussed in the preceding section, it also must affect a “term, condition, or privilege” of employment. 118

In Meritor Savings Bank, FSB v. Vinson , the Supreme Court discussed two examples of unlawful harassment: (1) an explicit change to the terms or conditions of employment that is linked to harassment based on a protected characteristic, e.g., firing an employee because the employee rejected sexual advances; and (2) conduct that constructively 119 changes the terms or conditions of employment through creation of a hostile work environment. [120]

The first type of claim was initially described as “quid pro quo” harassment in the context of sexual harassment. [121] In early sexual harassment cases, quid pro quo described a claim in which a supervisor carried out an adverse change to an employee’s compensation, terms, conditions, or privileges of employment because the employee rejected the supervisor’s sexual advances. [122]

However, citing the Supreme Court’s 1998 decision in Burlington Industries, Inc. v. Ellerth , the Second Circuit later explained that a quid pro quo allegation now only “makes a factual claim about the particular mechanism by which a plaintiff’s sex became the basis for an adverse alteration of the terms or conditions of [the plaintiff’s] employment.” [123] The underlying issue in a quid pro quo allegation is the same as in any claim of disparate treatment (i.e., intentional discrimination): whether the claimant has satisfied the statutory requirement of establishing “discriminat[ion] . . . because of . . . sex” affecting the “terms [or] conditions of employment.” [124] For example, if a supervisor denies an employee a promotion or other job benefit for rejecting sexual advances, the denial of the job benefit itself is an explicit change to the terms and conditions of employment and thus constitutes unlawful sex discrimination. [125]

To be actionable absent such an explicit change to the terms or conditions of employment, the harassment must change the terms or conditions of employment by creating a hostile work environment. The Supreme Court explained in 1993 in Harris v. Forklift Systems, Inc. that to establish a hostile work environment, offensive conduct must be both subjectively hostile and objectively hostile. 126

Conduct that is not severe or pervasive enough to create an objectively hostile or abusive work environment—an environment that a reasonable person would find hostile or abusive—is beyond Title VII’s purview. Likewise, if the victim does not subjectively perceive the environment to be abusive, the conduct has not actually altered the conditions of the victim’s employment, and there is no Title VII violation. [127]

The EEO statutes are therefore not limited to discriminatory conduct that has tangible or economic effects and instead “strike at the entire spectrum of disparate treatment.” [128] However, these statutes do not impose a general civility code that covers “run-of-the-mill boorish, juvenile, or annoying behavior.” [129] As discussed below in section III.B.3, the standard established in Harris takes a “middle path” that requires the conduct to be more than merely offensive but does not require that the conduct cause psychological harm. [130]

These are key questions that typically arise in evaluating a hostile work environment claim and whether it amounts to unlawful harassment:

• Objective hostility: was the conduct sufficiently severe or pervasive to create a hostile work environment from the perspective of a reasonable person?
• Subjective hostility: did the complainant actually find the conduct hostile?
• Can conduct that occurred outside the workplace be considered?
• Can conduct that was not specifically directed at the complainant be considered?

A wide variety of conduct by supervisors, coworkers, or non-employees that affects the workplace can contribute to a hostile work environment, including physical or sexual assaults or threats; offensive jokes, slurs, epithets, or name calling; intimidation, bullying, ridicule, or mockery; insults or put-downs; ostracism; offensive objects or pictures; and interference with work performance.

A hostile work environment claim also can include conduct that is independently actionable as disparate treatment. For example, if a woman was subjected to offensive sex-based comments and demoted because she refused to submit to unwanted sexual advances, the demotion would be independently actionable as sex discrimination (disparate treatment) and also actionable as part of a hostile work environment. [131]

The EEO laws prohibit harassment resulting in a work environment that is both subjectively and objectively hostile.

Example 36: Employee Was Subjected to Both Subjectively and Objectively Hostile Work Environment. Chadwick, who is Black, was recently hired as a sommelier and wine program director at an upscale restaurant. The restaurant is co-owned by Mark, who comes to check in on his investment approximately every three months. Mark arrives for a visit as the staff is preparing to open for evening service. Upon seeing Chadwick, whom Mark has not met before, Mark loudly asks, “Which dumbass manager is hiring n****rs for customer service positions now?” Mark continues on a racist diatribe that the entire staff can hear, leaving Chadwick humiliated and in tears. Based on these facts, Chadwick has been subjected to conduct that creates both a subjectively hostile work environment and an objectively hostile work environment and therefore the conduct has resulted in a hostile work environment that violates Title VII.

Although a complainant alleging a hostile work environment must show that the harassment was unwelcome, conduct that is subjectively and objectively hostile also is necessarily unwelcome. In the Commission’s view, demonstrating unwelcomeness is logically part of demonstrating subjective hostility. If, for example, a complainant establishes that a series of lewd, sexist, and derogatory comments based on sex were subjectively hostile, then those comments also would be, by definition, unwelcome. In some circumstances, evidence of unwelcomeness also may be relevant to the showing of objective hostility. 132

The unwelcomeness inquiry derives from the Supreme Court’s 1986 decision in Meritor Savings Bank, FSB v. Vinson , where the Court stated that “[t]he gravamen of any sexual harassment claim is that the alleged sexual advances were ‘unwelcome,’” 133 and from the 1980 EEOC Guidelines upon which the Court relied. 134 In Meritor , the Court distinguished the concept of unwelcomeness from the concept of voluntariness, noting that the complainant’s participation in the challenged conduct did not necessarily mean that she found it welcome. 135 When the Supreme Court refined the hostile work environment analysis in 1993, in Harris v. Forklift Systems, Inc. , to require a showing that the conduct was both subjectively and objectively hostile, 136 the Court did not explicitly eliminate unwelcomeness as the gravamen of a harassment claim.

Following Harris , a number of courts have addressed unwelcomeness as part of determining subjective hostility, because conduct that is subjectively hostile will also, necessarily, be unwelcome. 137 Other courts continue to analyze “unwelcomeness” as a separate element in a plaintiff’s prima facie harassment case, in addition to the “subjectively and objectively hostile work environment” analysis. 138 In the Commission’s view, this latter approach incorporates an unnecessary step in a court’s legal analysis of workplace harassment.

In general, the complainant’s own statement that the complainant perceived conduct as hostile is sufficient to establish subjective hostility. [139] A subjectively hostile work environment also may be established if there is evidence that an individual made a complaint about the conduct, as it follows logically that the individual found it hostile. 140 Similarly, if there is evidence that the individual complained to family, friends, or coworkers about the conduct, it is likely that the individual found it subjectively hostile. 141 To be clear, although evidence of contemporaneous complaints may be sufficient to show subjective hostility, such evidence is not necessary.

Whether conduct is subjectively hostile depends on the perspective of the complainant. Thus, if a male complainant does not welcome sexual advances from a female supervisor, it is irrelevant for the subjectivity analysis whether other men in the workplace would welcome these advances. [142] In addition, the fact that a complainant tolerated or even participated in the conduct does not necessarily mean that he did not find it hostile; for example, an employee might have experienced derogatory comments or other conduct targeted at the employee’s racial or national origin group as hostile but felt that there was no other choice but to “go along to get along.” 143 By contrast, if there is evidence that the complainant did not find the harassment to be hostile, such as the complainant’s statement that the complainant did not feel harassed by the challenged conduct, then subjective hostility may be at issue. [144]

A complainant’s subjective perception can change over time. For example, a complainant who did not perceive certain conduct as unwelcome in the past might subsequently perceive similar conduct as hostile after a certain point in time, such as after the end of a romantic relationship, [145] or where a colleague’s race-based jokes are initially dismissed as poor attempts at humor, but become unwelcome when they persist or are later accompanied by additional race-based conduct. Moreover, although the complainant may welcome certain conduct, such as sexually tinged conduct, from a particular employee, that does not mean that the complainant also would welcome it from other employees. [146] Nor does acceptance of one form of sexually tinged conduct mean that the complainant would welcome all sexually tinged conduct, particularly conduct of a more severe nature. [147]

Even if a complainant subjectively finds conduct based on a protected characteristic to be hostile, the conduct does not constitute a violation of federal EEO law unless it is also sufficiently severe or pervasive to create an objectively hostile work environment. [148]

Conduct need not be both severe and pervasive to establish a hostile work environment: the legal standard is severe or pervasive. The more severe the harassment, the less pervasive it must be, and vice versa. [149] There is neither a “magic number” of harassing incidents that automatically establishes a hostile work environment nor a minimum threshold for severity. [150] Whether a series of incidents is sufficiently severe or pervasive to create a hostile work environment depends on the specific facts of each case, viewed in light of the totality of the circumstances. 151

The issue of whether conduct creates a hostile work environment depends on the totality of the circumstances, as viewed from the perspective of a reasonable person, and no single factor is determinative. 152 Some relevant factors are the frequency and severity of the conduct; the degree to which the conduct was physically threatening or humiliating; the degree to which the conduct interfered with an employee’s work performance; and the degree to which it caused an employee psychological harm. [153] Another relevant factor is whether there is a power disparity—and its extent—between the harasser and the person harassed. [154] These factors are not exhaustive, and “no single factor is required” to establish an objectively hostile work environment. [155]

If harassing acts are based on multiple protected characteristics, and the acts are sufficiently related to be considered part of the same hostile work environment, then all the acts should be considered together in determining whether the conduct created a hostile work environment. [156] For example, if an employee alleges that her supervisor subjected her to harassing conduct based on both race and sex, then the combined effect of the alleged race-based and sex-based harassment should be considered, even if the employee cannot establish that either the race-based harassment or sex-based harassment, standing alone, is sufficiently severe or pervasive. 157

Example 37: Sex-Based Remark Does Not Create Hostile Work Environment. Roxana and Liam, both audio and video technicians at a broadcast news station, are in a heated meeting about upcoming holiday programming. After Roxana makes a suggestion with which Liam disagrees, Liam says to Roxana, “It must be your time of the month, are you on the rag?” Although harassment based on menstruation can constitute or contribute to a hostile work environment based on sex, 158 Liam’s lone remark is insufficient to create an objectively hostile work environment, despite being offensive.

Example 38: Age-Based Harassment Creates Hostile Work Environment. Henry, age sixty-two, is a consultant at a professional services company. Ryan, his supervisor, calls him “old man” on a periodic basis. Since Henry’s sixtieth birthday, Ryan has repeatedly asked him when he plans to retire, saying he can’t wait to bring in “young blood” and “fresh ideas.” During a recent staff meeting, Ryan reminded staff to get their flu shots, then looked at Henry and said, “Although I wouldn’t be heartbroken if the flu took out some of the old timers.” Henry asked Ryan if he was referring to him, and Ryan replied, “Absolutely, old man.” Henry reports feeling targeted and ashamed by Ryan’s comments. Based on these facts, Ryan has subjected Henry to an objectively hostile work environment based on age. 159

A complainant need not show that discriminatory conduct harmed the complainant’s work performance to prove an objectively hostile work environment if the evidence otherwise establishes that the conduct was sufficiently severe or pervasive to alter the terms or conditions of the complainant’s employment. [160] Similarly, actionable harassment can be established in the absence of psychological injury, though evidence of psychological harm from the harassment may be relevant to demonstrating a hostile work environment. [161]

Example 39: Hostile Work Environment Created Even Though Complainant Continued to Perform Well. Irina works as a sales representative for a freight transportation company. She and her coworkers sit in adjacent cubicles. Her coworkers, both men and women, often discuss their sexual liaisons; use sex-based epithets when describing women; and look at pornographic materials. Irina was horrified by the loudness and vulgarity of the conduct, and she frequently left the office to sit in her car and decompress from her coworkers’ conduct. Despite this conduct, however, Irina could meet her daily and weekly quotas, and her work continued to be rated in her performance review as above average. Based on these facts, Irina was subjected to a hostile work environment. Although the harassing conduct did not result in a decline in her work performance or in psychological injury, the nature of the conduct and Irina’s reactions to it were sufficient to establish that the ongoing sexual conduct created a hostile work environment because the conduct made it more difficult for a reasonable person in Irina’s situation to do her job. [162]

i. In General

Because a “supervisor’s power and authority invests his or her harassing conduct with a particular threatening character,” [163] harassment by a supervisor or other individual with authority over the complainant typically has more impact on a complainant’s work environment than similar misconduct by an individual lacking such authority. [164] Moreover, the severity of the harassment may be heightened if the complainant reasonably believes that the harasser has authority over her, even if that belief is mistaken. [165]

The more directly harassment affects the complainant, the more likely it is to negatively affect the complainant’s work environment. Thus, harassment is generally more probative of a hostile work environment if it occurs in the complainant’s presence than if the complainant learns about it secondhand. Nevertheless, a complainant’s knowledge of harassing conduct that other employees have separately experienced may be relevant to determining the severity of the harassment in the complainant’s work environment. 166

Some conduct may be more severe if it occurs in the presence of others, such as the complainant’s coequals, subordinates, or clients. For example, a worker’s sexually degrading comments may be more severe if made in the presence of the complainant and the complainant’s subordinates rather than solely in the complainant’s presence, due to the humiliating nature of the interaction. [167] Conversely, some conduct may be more severe when the complainant is alone with the offending individual because the isolation may enhance the threatening nature of the discriminatory conduct. 168

Because the severity of harassment depends on all of the circumstances, the considerations discussed above are not exclusive. Other factors may be relevant in evaluating the severity of alleged harassment. For example, harassment may be more severe if a complainant has reason to believe that the harasser is insulated from corrective action. This could arise if the harasser is a highly valued employee, or the employer has previously failed to take appropriate corrective action in similar circumstances. [169]

ii. Hostile Work Environment Based on a Single Incident of Harassment

In limited circumstances, a single incident of harassment can result in a hostile work environment. The following is a non-exhaustive list of examples of conduct that courts have found sufficiently severe to establish a hostile work environment based on a single incident:

• Sexual assault, 170
• Sexual touching of an intimate body part, [171]
• Physical violence or the threat of physical violence, [172]
• The display of symbols of violence or hatred, such as a swastika, an image of a Klansman’s hood, or a noose, [173]
• The use of denigrating animal imagery, such as comparing the employee to a monkey, ape, or other animal, [174]
• A threat to deny job benefits for rejecting sexual advances, [175] and
• The use of the “n-word” by a supervisor in the presence of a Black subordinate. 176

Using epithets based on protected characteristics is a serious form of workplace harassment. As stated by one court, epithets are “intensely degrading, deriving their power to wound not only from their meaning but also from ‘the disgust and violence they express phonetically.’” [177]

More frequent but less serious incidents can create a hostile work environment, and most hostile work environment claims involve a series of acts. 178 The focus is on the cumulative effect of these acts, rather than on the individual acts themselves. As noted above, there is not a “magic number” of harassing incidents that automatically establishes a hostile work environment. [179] Whether a series of events is sufficiently severe or pervasive to create a hostile work environment depends on the specific facts of each case. [180] Relevant considerations may include the frequency of the conduct [181] and the relationship between the number of incidents and the time period over which they occurred. 182

Example 40: Hostile Work Environment Created by Pervasive Sexual Harassment. Juan, who works as a passenger service assistant for an airline, alleges that Lydia, a female coworker who shares the same schedule, sexually harassed him for several weeks. The evidence shows that Lydia directed sexual overtures and other sex-based conduct at Juan as often as several times a week, despite his repeated statements that he was not interested. For example, Lydia gave Juan revealing photographs of herself, sent him notes asking for a date, described fantasies about him, and persistently told him how attractive he was and how much she loved him. Based on these facts, the conduct was sufficiently pervasive to create a hostile work environment. [183]

Example 41: Sexual Favoritism Creating a Hostile Work Environment. Tasanee, an employee at a government agency, alleges that she has been subjected to a hostile work environment based on her sex. The evidence shows that supervisors engaged in consensual sexual relationships with female subordinates that were publicly known and behaved in sexually charged ways with other agency employees in public. Supervisors rewarded the subordinates who were in relationships or who acceded without objection to the behavior by granting them promotions, awards, and other benefits. Because the conduct was pervasive and could reasonably affect the work performance and motivation of other women workers who found the favoritism offensive, the evidence is sufficient to show that Tasanee was subjected to a sex-based hostile work environment. 184

The harassment being challenged must create an objectively hostile work environment from the perspective of a reasonable person in the complainant’s position. 185 The impact of harassment must be evaluated in the context of “surrounding circumstances, expectations, and relationships.” [186] Discussed below are some significant aspects of context that can be relevant in determining whether harassment was sufficiently severe or pervasive to create a hostile work environment. Other considerations also may be relevant in evaluating harassment in light of the totality of the circumstances.

The determination of whether harassment was objectively hostile requires “an appropriate sensitivity to social context” 187 and should be made from the perspective of a reasonable person of the complainant’s protected class. [188] Thus, if a Black individual alleges racial harassment, the harassment should be evaluated from the perspective of a reasonable Black individual in the same circumstances as the complainant. Conduct can establish a hostile work environment as to the complainant even if some members of the complainant’s protected class did not or would not find it to be hostile. [189]

In addition to protected status, other personal or situational 190 characteristics of a particular complainant may affect whether the complainant reasonably perceives certain conduct as creating a hostile work environment. For example, if a teenager was harassed by a substantially older individual, then the age difference may intensify the perceived hostility of the behavior. [191] Similarly, if an undocumented worker is targeted by harassment, then the heightened risk of deportation may contribute to objective hostility. [192]

Example 42: Religion-Based Harassment Creates an Objectively Hostile Work Environment. Josephine, an IT support specialist at a regional medical facility, attends an employee appreciation barbecue lunch hosted by her employer. When asked by colleagues why she is not eating any of the barbecued pork, Josephine explains that she is Jewish and her religion’s dietary laws prohibit eating pork. After the barbecue, a few coworkers begin making comments to or within earshot of Josephine, such as calling Josephine “Jew-sephine,” questioning why Josephine even works because she must have a lot of “Jew money” 193 in the bank, and stating that “Jews control the media.” Based on these facts, this conduct, viewed from the perspective of a reasonable Jewish person, created an objectively hostile work environment based on religion.

Example 43: Disability-Based Harassment Creates an Objectively Hostile Work Environment. Jin, a cook, has Post-Traumatic Stress Disorder (PTSD). He tells his coworkers that he served in Iraq on active duty, has PTSD, and, as a result, is uncomfortable with sudden loud noises and unanticipated physical contact. He asks them to tell him in advance about any anticipated loud noises, and requests that they avoid approaching him from behind without warning. Lila, a server, regularly drops or bangs on metal trash cans and sneaks up behind Jin while he is working, because she thinks his response is funny. Jin is so rattled after these encounters that he sometimes mixes up orders or fails to cook the food properly. Jin repeatedly tells Lila to stop, to no avail, and the conduct continues. Based on these facts, Lila’s harassment, viewed from the perspective of a reasonable person with PTSD, has created an objectively hostile work environment based on disability.

Example 44: National-Origin-Based Harassment Creates an Objectively Hostile Work Environment. Somchai, a Thai national, performs seasonal agriculture work at a sweet potato farm and has an H-2B visa. Somchai is told that his employer specifically recruits individuals from Thailand because they are obedient and submissive and have a good work ethic. At the worksite, Somchai is subject to frequent physical and verbal abuse, including epithets such as “slant eyes” and “rice eater.” Further, if Somchai’s supervisor observes Somchai pausing in his work, even to use the bathroom or eat lunch, the supervisor threatens to have Somchai’s visa revoked, saying, “That will turn you into an ‘illegal’ so I can call ICE and have you arrested and deported.” 194 Based on these facts, the national-origin-based harassment experienced by Somchai, which is compounded by Somchai’s vulnerability as a migrant worker and visa holder, is sufficiently severe or pervasive to create an objectively hostile work environment.

Example 45: Sex-Based Harassment Creates an Objectively Hostile Work Environment. Velma, a technician at a metal fabrication company, has recently been subjected to dating violence by her long-term intimate partner, which resulted in Velma moving out of their shared residence and into a shelter. Velma’s coworker, Dan, learns about Velma’s current living situation and, viewing her as vulnerable, asks Velma out on a date. Despite Velma declining his request, during each shift that they work together, Dan continues to say things like, “Is living in a shelter really worse than cuddling me at night?”; “I’ll let you live with me free of charge on one condition: that you clean my house while naked”; and “the only thing that I would ever hit is that ass.” Based on these facts, the sex-based harassment experienced by Velma, which must be viewed in the context of her vulnerability as a survivor of dating violence, is sufficiently severe or pervasive to create an objectively hostile work environment.

Example 46: Harassment Based on Gender Identity Creates an Objectively Hostile Work Environment. Jennifer, a female cashier who is transgender and works at a fast-food restaurant, is regularly and intentionally misgendered by supervisors, coworkers, and customers over a period of several weeks. One of her supervisors, Allison, intentionally and frequently uses Jennifer’s prior male name, male pronouns, and “dude” when referring to Jennifer, despite Jennifer’s requests for Allison to use her correct name and pronouns. Other managers also intentionally refer to Jennifer as “he” whenever they work together. In the presence of customers, coworkers ask Jennifer questions about her sexual orientation and anatomy and assert that she is not female. After hearing these remarks by employees, customers also intentionally misgender Jennifer and make offensive comments about her transgender status. Based on these facts, which must be viewed in the context of Jennifer’s perspective as a transgender individual, Jennifer has been subjected to an objectively hostile work environment based on her gender identity that includes repeated and intentional misgendering. 195

Conduct also must be evaluated in the context of the specific work environment in which it occurred. For example, in some instances, conduct may be more likely to create a hostile work environment if the complainant works in a remote location alone with the harasser. 196 There is, however, no “crude environment” exception to Title VII. 197 Prevailing workplace culture, likewise, does not excuse discriminatory conduct. [198] Thus, public displays of pornography or sexually suggestive imagery demeaning women can contribute to an objectively hostile work environment for female employees, even if it is a long-standing practice. 199

As discussed above in section III.B.1, in the Commission’s view, demonstrating unwelcomeness is logically an inherent part of demonstrating subjective hostility. In some circumstances, evidence of unwelcomeness also may be relevant to the showing of objective hostility. [200] When analyzing whether conduct is objectively hostile, some courts have focused on whether the harasser had notice that the conduct was unwelcome—either because the complainant had communicated as much or the harasser otherwise had reason to know. 201 Such notice may be relevant in determining whether it is objectively reasonable for a person in the complainant’s position to have perceived the ongoing conduct as hostile. [202] For example, flirtatious behavior or asking an individual out on a date may, or may not, be facially offensive, depending on the circumstances. An individual’s continued flirting or asking for a date after notice that this conduct was unwelcome can support a determination that a reasonable person in the complainant’s position would perceive the conduct as hostile. 203

The same may be true in the context of religious expression. If a religious employee attempts to persuade another employee of the correctness of his beliefs, the conduct is not necessarily objectively hostile. If, however, the employee objects to the discussion but the other employee nonetheless continues, a reasonable person in the complainant’s position may find it to be hostile. [204]

Example 47: Religious Expression Does Not Create an Objectively Hostile Work Environment. Ellen, an observant Lutheran, works as a nurse in a retirement community where the majority of staff are Muslim. Some of Ellen’s Muslim colleagues pray in accordance with their religious beliefs in a designated room observable from the nurse’s station, which Ellen sometimes finds distracting. Ellen’s Muslim colleagues also coordinate an optional lunchtime Qur’an study group, which all employees are invited to join. After Ellen declines the group’s invitation, stating that she studies the Bible at home, she is not invited to the Qur’an study group again. On occasion, and sometimes within Ellen’s earshot, Ellen’s Muslim colleagues openly discuss their religious beliefs in a manner that does not disparage others. Ellen tells her supervisor that she finds these discussions of religion in the workplace to be “disruptive.” Based on these facts, the religious expression of Ellen’s Muslim colleagues does not create an objectively hostile work environment for Ellen.

Example 48: Religious Expression Creates an Objectively Hostile Work Environment. Same facts as above, however, after Ellen declines the invitation to attend the optional lunchtime Qur’an study group, Sayiddah, a colleague, openly admonishes Ellen for not believing in Allah and repeatedly warns her that she is “on the wrong spiritual path.” 205 Ellen asks Sayiddah to stop discussing religion with her; however, Sayiddah says she will not, explaining that her prayers come from a place of love and that she has a religious obligation to spread the word of Islam to non-believers. Based on these facts, Sayiddah’s religious expression creates an objectively hostile work environment for Ellen.

Because separate incidents that make up a hostile work environment claim constitute a single unlawful employment practice, the complainant can challenge an entire pattern of conduct, as long as at least one incident that contributed to the hostile work environment is timely. [206] The earlier conduct, however, must be sufficiently related to the later conduct to be “part of the same actionable hostile work environment practice” claim. 207 Relevant considerations depend on the specific facts but may include the similarity of the actions involved, the frequency of the conduct, and whether the same individuals engaged in the conduct. [208]

A hostile work environment claim may include hostile conduct that affects the complainant’s work environment, even conduct that may be independently actionable as unlawful discrimination (disparate treatment), as long as it is part of an overall pattern of harassing conduct. For example, a racially discriminatory transfer to a less desirable position that is separately actionable also may contribute to a racially hostile work environment if the action was taken by a supervisor who frequently used racial slurs. 209 Under such circumstances, the transfer could be challenged as part of a hostile work environment claim and would be considered in determining whether the entire course of conduct, including both the transfer and the repeated racial slurs, was sufficiently severe or pervasive to create a hostile work environment. In addition, if the transfer occurred within the filing period, then the complainant could also bring a separate claim alleging discriminatory transfer. For more information on the timeliness of hostile work environment claims, see EEOC, Compliance Manual Section 2: Threshold Issues § 2-IV.C.1.b (2009), https://www.eeoc.gov/policy/docs/threshold.html#2-IV-C-1-b .

Example 49: Earlier Harassment Was Sufficiently Related to Later Harassment. Rabia, a Muslim with Palestinian family ties, was subjected to offensive comments about her religion and ethnicity by her team leader in the packaging department, Josiah. Rabia complained to the plant manager, who did not take any action, and Josiah’s harassment continued. At her own request, Rabia was transferred to the stretch wrap department. Soon after, she saw Josiah speaking with Franklin, a stretch wrap employee, while pointing at Rabia and laughing. Starting the next day, Franklin regularly referred to Rabia using religious and ethnic slurs, including “m*zzie,” and “terrorist.” Franklin also refused to fill in for her when she needed to take a break. Rabia complained to the plant manager about Franklin’s conduct, but again the plant manager did not take any action. Here, Rabia experienced harassment in two different departments by different harassers, but the conduct was similar in nature. The harassment in the second department occurred shortly after the harassment in the first department; the harassment in the second department started after the two harassers met; and the plant manager was responsible for addressing harassment in both departments. Based on these facts, the harassment based on religion and national origin experienced by Rabia in the two departments constitutes part of the same hostile work environment claim. [210]

Example 50: Earlier Harassment Was Insufficiently Related to Later Harassment. Cassandra, who works for a printing company, was exposed to sexually explicit discussions, jokes, and vulgar language when she worked in the company’s production department. After Cassandra was transferred to the estimating department, she was no longer exposed to the harassing conduct she had experienced in the production department. However, while working in the estimating department, Cassandra overheard a male worker on the other side of her cubicle wall tell someone that if a weekend trip with one of his female friends “was not a sleepover, then she wasn’t worth the trip.” The sleepover comment was made nearly a year after Cassandra’s transfer and was not directed at Cassandra or made for her to hear. Other than that comment, Cassandra did not experience any alleged harassment after her transfer to the estimating department, which did not interact with the production department. Based on these facts the alleged harassment experienced by Cassandra in the production department was not part of the same hostile work environment claim as the alleged harassing conduct in the estimating department. [211]

Harassing conduct can affect an employee’s work environment even if it is not directed at that employee, although the more directly it affects the complainant, the more probative it will be of a hostile work environment. [212] For instance, the use of sex-based epithets may contribute to a hostile work environment for women even if the epithets are not directed at them. [213] Similarly, anonymous harassment, such as racist or anti-Semitic graffiti or the display of a noose or a swastika, may create or contribute to a hostile work environment, even if it is not clearly directed at any particular employees. [214] Offensive conduct that is directed at other individuals of the complainant’s protected class also may contribute to a hostile work environment for the complainant. Such conduct may even occur outside of the complainant’s presence as long as the complainant becomes aware of the conduct during the complainant’s employment and it is sufficiently related to the complainant’s work environment. 215

Example 51: Conduct Not Directed Against Complainant Contributes to a Hostile Work Environment. Peter is an Assistant District Manager for an insurance company. Peter, who is Black, oversees four sales representatives who also are Black. Peter reports to the District Manager, Lilliana, who is White. Over the two years that Peter has worked for the insurance company, Lilliana has used the term “n****r” when talking to Peter’s subordinates; she also told Peter that his “Black sales representatives are too dumb to be insurance agents”; and on another occasion she called the corporate office to ask them to stop hiring Black sales representatives. Some of the comments were made in Peter’s presence, and Peter learned about other comments secondhand, when sales representatives complained to him about them. Based on these facts, Lilliana’s conduct toward Peter’s subordinates contributed to a hostile work environment for Peter because the comments either occurred in Peter’s presence or he learned about them from others. 216

In some circumstances, an individual who has not personally been subjected to unlawful harassment based on their protected status may be able to file an EEOC charge and a lawsuit alleging that they have been harmed by unlawful harassment of a third party. [217]

Example 52: Individual Harmed by Unlawful Harassment of Third Party. Sophie works in an accounting office with her coworker Eitan, who is Jewish and the son of Israelis, and their mutual supervisor, Jordan. Jordan makes frequent offensive comments about Jews and Israel, asking Eitan repeatedly when he was going to “go home and start fighting.” One day, after referring to Eitan with an epithet used for Jews, Jordan tells Sophie to hide Eitan’s work files on the office server to “make his life difficult” and to reschedule a series of important team meetings so that they will conflict with Eitan’s scheduled time off, effectively excluding him from the meetings. Sophie objects, but Jordan tells her that “if you want a future here, you better do what I tell you.” Fearing workplace repercussions if she fails to comply, Sophie reluctantly participates in the ongoing national origin- and religion-based harassment of Eitan.

Sophie and Eitan both file EEOC charges. Eitan’s allegation is that he faced a hostile work environment based on national origin and religion; Sophie’s allegation is that Eitan faced a hostile work environment based on his national origin and religion and she was forced to participate in it. Based on evidence that the harassment occurred on a regular basis and included serious and offensive conduct, including harassment designed to interfere with Eitan’s work performance and ostracize him, the investigator concludes that Eitan was subjected to a hostile work environment based on his race and religion.

The investigator further concludes that, although Sophie was not personally subjected to unlawful harassment based on her race, religion, or other protected status, she had standing to file a charge and obtain relief for any harm she suffered as a result of the unlawful harassment of Eitan because she was required, as part of her job duties, to participate in the harassment. [218]

A hostile work environment claim may include conduct that occurs in a work-related context outside an employee’s regular workplace. [219] For instance, harassment directed at an employee during the course of offsite employer-required training occurs within the “work environment,” even if the training is not conducted at the employer’s facility. [220]

Example 53: Harassment During Off-Site Employer-Hosted Party Was Within Work Environment. Fatima’s employer hosts its annual holiday party in a private restaurant. One of her coworkers, Tony, drinks to excess, and at the end of the evening attempts to grope and kiss Fatima. Although Tony’s behavior occurred outside Fatima’s regular workplace and at a private restaurant unaffiliated with her employer, it occurred in a work-related context, the company-sponsored holiday party. Therefore, based on these facts, the harassment occurred in Fatima’s work environment for purposes of a Title VII sexual harassment claim.

Example 54: Harassment During Non-Work Hours at Employer-Provided Housing Was Within Work Environment. Rosa is a seasonal farmworker who resides in employer-provided housing a few miles away from the farm where she works. Rosa’s employer requires all seasonal farmworkers to live in employer-provided housing, which is a converted former motel, and deducts “rent” from their paychecks. Another seasonal worker, Lucas, follows Rosa around the housing complex, waiting for her outside of her room and in the parking lot. Rosa reports Lucas’s behavior to management and complains that she feels unsafe, but no action is taken. Lucas’s behavior escalates, and he sexually assaults Rosa during non-working hours at the housing complex. Although Lucas’s conduct occurred outside of the workplace, it occurred in a work-related context. Therefore, based on these facts, the harassment occurred in Rosa’s work environment.

Conduct also occurs within the work environment if it is conveyed using work-related communications systems, accounts, devices, or platforms, such as an employer’s email system, electronic bulletin board, instant message system, videoconferencing technology, intranet, public website, official social media accounts, or other equivalent services or technologies. [221] As with a physical work environment, conduct within a virtual work environment can contribute to a hostile work environment. This can include, for instance, sexist comments made during a video meeting, ageist or ableist comments typed in a group chat, racist imagery that is visible in an employee’s workspace while the employee participates in a video meeting, or sexual comments made during a video meeting about a bed being near an employee in the video image.

Example 55: Conduct on Employer’s Email System Was Within the Work Environment. Ted and Perry are coworkers in an architectural firm. Ted is White, and Perry is Black. Every Monday morning, Ted sends jokes from his work computer and work email account to colleagues, including Perry. Many of the jokes involve racial stereotypes, including stereotypes about Black individuals. Perry complains to Ted and their mutual supervisor after several weeks of Ted’s emails, but Ted is not instructed to stop and continues to send such emails. Based on these facts, the racial jokes sent by Ted occurred within Perry’s work environment because, among other reasons, they were sent using Ted’s work computer and work email account and were sent to Perry and other colleagues in the workplace.

Although employers generally are not responsible for conduct that occurs in a non-work-related context, they may be liable when the conduct has consequences in the workplace and therefore contributes to a hostile work environment. 222 For instance, if a Black employee is subjected to racist slurs and physically assaulted by White coworkers who encounter him on a city street, the presence of those same coworkers in the Black employee’s workplace can result in a hostile work environment. [223]

Conduct that can affect the terms and conditions of employment, even if it does not occur in a work-related context, includes electronic communications using private phones, computers, or social media accounts, if it impacts the workplace. 224 For example, if an Arab American employee is the subject of ethnic epithets that a coworker posts on a personal social media page, and either the employee learns about the post directly or other coworkers see the comment and discuss it at work, then the social media posting can contribute to a hostile work environment based on national origin. However, postings on a social media account generally will not, standing alone, contribute to a hostile work environment if they do not target the employer or its employees.

Example 56: Conduct on Social Media Platform Outside Workplace Contributes to Hostile Work Environment. Rochelle, a Black woman born in the United States, works at a tax firm. She alleges that two Black coworkers of Caribbean descent, Martina and Terri, subjected her to a hostile work environment based on national origin. The investigation reveals that Martina’s and Terri’s harassing conduct included mocking Rochelle, blocking doorways, and interfering with her work, and that it culminated in an offensive post on a popular social media service that they all use. In the post, Martina and Terri included two images of Rochelle juxtaposed with an image of the fictional ape Cornelius from the movie The Planet of the Apes , along with text explicitly comparing Rochelle to Cornelius. Rochelle learned about the post from another coworker, Jenna. Based on these facts, the combined conduct, including the social media post, was sufficient to create a hostile work environment. 225

Example 57: Conduct on Social Media Platform Outside Workplace Does Not Contribute to Hostile Work Environment. Michael, a courier for a management consulting firm, believes that women should dress conservatively on romantic dates and limit their food intake to appear lady-like. Michael shares these beliefs in posts on his private social media accounts. He also shares posts criticizing women’s sexual behavior, such as stating, “Why would a man buy a cow when you can get the milk for free?” Michael’s coworker Donna finds some of Michael’s posts online and is deeply offended even though there is no connection between the posts and the firm or any of its employees, and Michael has never spoken to Donna about these views. These posts, on their own, do not contribute to a hostile work environment based on sex because they do not have an impact on Donna’s work environment.

Given the proliferation of technology, it is increasingly likely that the non-consensual distribution of real or computer-generated intimate images, such as through social media, messaging applications, or other electronic means, can contribute to a hostile work environment, if it impacts the workplace.

Example 58: Conduct on Social Media Platform Outside Workplace Contributes to Hostile Work Environment. Max, a line cook at a restaurant, begins dating Anne, a server who works at the same restaurant. During their relationship, Max obtains sexually explicit images of Anne. After Anne breaks up with Max, he threatens to share the images on social media unless she gives him a second chance. When she refuses, he posts the images on a picture-sharing social media application and tags some of their coworkers. Anne overhears her coworkers making fun of the images and talking about how Anne must have poor judgment. Anne is humiliated and finds it difficult to continue to return to work. Based on these facts, the combined conduct, including the social media post, was sufficient to create a hostile work environment. 226

Finally, harassment by a supervisor that occurs outside the workplace is more likely to contribute to a hostile work environment than similar conduct by coworkers, given a supervisor’s ability to affect a subordinate’s employment status. 227

When a complainant establishes that the employer made an explicit change to a term, condition, or privilege of employment linked to harassment based on a protected characteristic (sometimes described as “quid pro quo,” as explained in section III.A), the employer is liable and there is no defense. 228

In cases alleging a hostile work environment, one or more standards of liability will apply. Which standards apply to any given situation depends on the relationship of the harasser to the employer and the nature of the hostile work environment. Each standard is discussed in detail in sections IV.B and IV.C, below. To summarize:

• If the harasser is a proxy or alter ego of the employer, the employer is automatically liable for the hostile work environment created by the harasser’s conduct. The actions of the harasser are considered the actions of the employer, and there is no defense to liability.
• If the harasser is a supervisor and the hostile work environment includes a tangible employment action against the victim, the employer is vicariously liable for the harasser’s conduct and there is no defense to liability. This is true even if the supervisor is not a proxy or alter ego.
• If the harasser is a supervisor (but not a proxy or alter ego) and the hostile work environment does not include a tangible employment action, the employer is vicariously liable for the actions of the harasser, but the employer may limit its liability or damages if it can prove the Faragher-Ellerth affirmative defense, which is explained below at section IV.C.2.b.
• If the harasser is any person other than a proxy, alter ego, or supervisor, the employer is only liable for the hostile work environment created by the harasser’s conduct if the employer was negligent in that it failed to act reasonably to prevent the harassment or to take reasonable corrective action in response to the harassment when the employer was aware, or should have been aware, of it.

Negligence provides a minimum standard for employer liability, 229 regardless of the status of the harasser. 230 Other theories of employer liability—automatic liability (for proxies and alter egos) and vicarious liability (for supervisors)—are additional bases for employer liability that supplement 231 and do not replace the negligence standard. 232

If the complainant challenges harassment by one or more supervisors and one or more coworkers or non-employees and the harassment is part of the same hostile work environment claim, [233] separate analyses of employer liability should be conducted in accordance with each harasser’s classification. 234

The liability standard for a hostile work environment depends on whether the harasser is a:

• Proxy or alter ego of the employer;
• Supervisor; or
• Non-supervisory employee, coworker, or non-employee.

The applicable standards of liability depend on the level and kind of authority that the employer afforded the harasser to act on its behalf.

An individual is considered an alter ego or proxy of the employer if the individual possesses such high rank or authority that his or her actions can be said to speak for the employer. [235] Individuals who might be considered proxies include sole proprietors and other owners; partners; corporate officers; and high-level managers whose authority or influence within the organization is such that their actions could be said to “speak for” the employer. [236] By contrast, a supervisor does not qualify as the employer’s alter ego merely because the supervisor exercises significant control over the complaining employee. [237]

In the context of employer liability for a hostile work environment, an employee is considered a “supervisor” if the individual is “empowered by the employer to take tangible employment actions against the victim.” [238] An employee may, of course, have more than one supervisor.

A “tangible employment action” means a “significant change in employment status” that requires an “official act” of the employer. 239 Examples of tangible employment actions include hiring and firing, failure to promote, demotion, reassignment with significantly different responsibilities, a compensation decision, and a decision causing a significant change in benefits. 240 In some cases, a decision may constitute a tangible employment action even though it does not have immediate direct or economic consequences, such as a demotion with a substantial reduction in job responsibilities but without a loss in pay. [241]

Even if an individual is not the final decision maker as to tangible employment actions affecting the complainant, the individual would still be considered a supervisor if the individual has the “power to recommend or otherwise substantially influence tangible employment actions.” 242

Finally, an employee who does not have actual authority to take a tangible employment action with respect to the complainant can still be considered a supervisor if, based on the employer’s actions, the harassed employee reasonably believes that the harasser has such power. 243 The complainant might have such a reasonable belief where, for example, the chain of command is unclear or the harasser has broad delegated powers. [244] In these circumstances, the harasser is said to have “apparent authority.” 245

Federal EEO laws protect employees against unlawful harassment by other employees who do not qualify as proxies/alter egos or “supervisors,” i.e., other employees without actual or apparent authority to take tangible employment actions against the employee(s) subjected to the harassment. These other employees may include coworkers with no authority over the complainant as well as shift leads or other workers with limited authority over the complainant. Employees are further protected against unlawful harassment by non-employees, such as independent contractors; [246] customers, [247] including hotel guests, airline passengers, and shoppers; students; [248] hospital patients and nursing home residents; [249] and clients of the employer. [250]

Example 59: Harassment by a Non-Employee. Howard works as a stocker for a company that sells snacks and beverages in vending machines on customers’ premises. At a hospital where Howard is assigned to stock the vending machines, he is harassed daily by a hospital employee who knows Howard’s schedule and waits at the vending machines for him to arrive. The hospital employee calls him “H*mo Howard,” propositions him, and makes lewd and vulgar sexual comments to him every time the hospital employee sees him. Howard reports this harassment to his employer. Although the harasser is not employed by Howard’s employer, because Howard’s employer is aware of the sex-based harassment, it has a legal obligation to correct the harassment. 251

Example 60: Harassment by a Non-Employee. While cleaning a guest room, Paloma, a housekeeper at a hotel, is cornered by a naked guest who propositions her for sex. Paloma immediately reports this conduct to her supervisor. Although the guest is not an employee of the hotel, because Paloma’s employer is aware of the sex-based harassment, it has a legal obligation to correct the harassment.

Once the status of the harasser is determined, the appropriate standard can be applied to assess employer liability for a hostile work environment.

If the harasser is an alter ego or proxy of the employer, the employer is automatically liable for unlawful harassment and has no defense. 252 Thus, a finding that the harasser is an alter ego or proxy is the end of the liability analysis. This is true whether or not the harassment includes a tangible employment action.

Example 61: Harasser Was Employer’s Alter Ego. Gina, who is Peruvian-American, alleges that she was subjected to unlawful harassment because of her national origin by the company Vice President, Walter. Walter is the only corporate Vice President in the organization, answers only to the company’s President, and exercises managerial responsibility over the company’s operations. Based on these facts, given Walter’s high rank within the company and his significant control over the company’s operations, Walter is an alter ego of the company, subjecting it to automatic liability for a hostile work environment resulting from his harassment.

An employer is vicariously liable for a hostile work environment created by a supervisor. 253 Under this standard, liability for the supervisor’s harassment is attributed to the employer. As discussed below, unlike situations where the harasser is an alter ego or proxy of the employer, an employer may have an affirmative defense, known as the Faragher-Ellerth defense, when the harasser is a supervisor. The availability of the Faragher-Ellerth defense is dependent on whether the supervisor took a tangible employment action against the complainant as part of the hostile work environment. If the Faragher-Ellerth defense is available, the employer bears the burden of proof with respect to the elements of that defense.

If the supervisor took a tangible employment action as part of the hostile work environment, then the employer is automatically liable for the hostile work environment and does not have a defense.

If the supervisor did not take a tangible employment action , then the employer can raise the Faragher-Ellerth affirmative defense to vicarious liability by proving both of the following:

• The employer acted reasonably to prevent and promptly correct harassment; and
• The complaining employee unreasonably failed to use the employer’s complaint procedure or to take other steps to avoid or minimize harm from the harassment.

An employer is always liable if a supervisor’s harassment creates a hostile work environment that includes a tangible employment action. [254] As previously noted, agency principles generally govern employer liability for a hostile work environment. The Supreme Court stated in Ellerth that “[w]hen a supervisor makes a tangible employment decision, there is assurance the injury could not have been inflicted absent the agency relation.” 255 Therefore, when a hostile work environment includes a tangible employment action, the “action taken by the supervisor becomes for Title VII purposes the act of the employer,” 256 and the employer is liable. 257

The tangible employment action may occur at any time during the course of the hostile work environment, and need not occur at the end of employment or serve as the culmination of the harassing conduct. [258] For example, if a supervisor subjects an employee to a hostile work environment by making frequent sexual comments and denying pay increases because the employee rejects the sexual advances, [259] then the employer is liable for the hostile work environment created by the supervisor and there is no defense. 260 This is true even though the supervisor’s tangible employment action, here denial of pay increases, did not occur at the end of the employee’s employment.

An unfulfilled threat to take a tangible employment action does not itself constitute a tangible employment action, but it may contribute to a hostile work environment. 261 By contrast, fulfilling a threat of a tangible employment action because a complainant rejects sexual demands (e.g., denying a promotion) constitutes a tangible employment action. Finally, fulfilling a promise to provide a benefit because the complainant submits to sexual demands (e.g., granting a promotion or not terminating the complainant after the complainant submits to sexual demands) constitutes a tangible employment action. [262]

If harassment by a supervisor creates a hostile work environment that did not include a tangible employment action, the employer can raise an affirmative defense to liability or damages. In Faragher and Ellerth , the Supreme Court explained that the defense requires the employer to prove that:

• the employer exercised reasonable care to prevent and correct promptly any harassment; and
• the employee unreasonably failed to take advantage of any preventive or corrective opportunities provided by the employer or to take other steps to avoid harm from the harassment. 263

In establishing this affirmative defense, the Supreme Court sought “to accommodate the agency principles of vicarious liability for harm caused by misuse of supervisory authority, as well as Title VII’s equally basic policies of encouraging forethought by employers and saving action by objecting employees.” 264 The Court held that this carefully balanced defense contains “two necessary elements:” 265 (1) the employer’s exercise of reasonable care to prevent and correct promptly any harassing behavior, and (2) the employee’s unreasonable failure to take advantage of any preventive or corrective opportunities provided by the employer or to avoid harm otherwise. 266 Thus, in circumstances in which an employer fails to establish one or both prongs of the affirmative defense, the employer will be liable for the unlawful harassment. For example, if the employer is able to show that it exercised reasonable care but cannot show that the employee unreasonably failed to take advantage of preventive or corrective opportunities, the employer will not be able to establish the defense.

Example 62: Employer Fails to Establish Affirmative Defense. Chidi, who is of Nigerian heritage, was subjected to national origin and racial harassment by his supervisor, Ang. The employer does not have a written anti-harassment policy and does not offer comprehensive anti-harassment training. Instead, employees are told to “follow the chain of command” if they have any complaints, which would require Chidi to report to Ang. During meetings with Chidi and his coworkers, Ang repeatedly directed egregious racial and national origin-based epithets at Chidi, and Ang’s conduct was sufficient to create a hostile work environment. Chidi reported Ang’s harassment to his manager (who was also Ang’s supervisor) on at least two separate occasions. Each time, the manager simply responded, “That’s just Ang—don’t take it seriously.” Based on these facts, the employer cannot establish either prong of the affirmative defense. The employer did not exercise reasonable care to prevent or to promptly correct the harassment. Further, the employer cannot establish that Chidi unreasonably failed to take advantage of the employer’s complaint process. Based on these facts, the employer is liable for Ang’s harassment of Chidi.

Example 63: Employer Avoids Liability by Establishing Affirmative Defense. Kit was subjected to a hostile work environment by their supervisor because of race. The supervisor’s harassment was not severe at first but grew progressively worse over a period of months. The employer had an effective anti-harassment policy and procedure, which it prominently displayed on its employee website and provided to all employees through a variety of other means. In addition, the employer was not aware of any harassment by this supervisor in the past. [267] Kit never complained to the employer about the harassment or took steps to avoid harm from the harassment. The employer learned of the supervisor’s conduct from Kit’s coworker, who observed the harassment. After learning about it, the employer took immediate corrective action that stopped the harassment. Based on these facts, the employer is not liable for the supervisor’s harassment of Kit, because the employer had an effective policy and procedure and took prompt corrective action upon receiving notice of the harassment and Kit could have used the effective procedure offered by the employer or taken other appropriate steps to avoid further harm from the harassment but did not do so.

i. First Prong of the Affirmative Defense: Employer’s Duty of Reasonable Care

The first prong of the affirmative defense requires an employer to show that it exercised reasonable care both to prevent harassment and to correct harassment. To do so, an employer must show both that it took reasonable steps to prevent harassment in general , as discussed immediately below, and that it took reasonable steps to prevent and to correct the specific harassment raised by a particular complainant. Because the questions of whether the employer acted reasonably to prevent and to correct the specific harassment alleged by the complainant also arise when analyzing employer liability for non-supervisor harassment, those issues are discussed in detail at section IV.C.3.a (addressing unreasonable failure to prevent harassment) and section IV.C.3.b (addressing unreasonable failure to correct harassment). The principles discussed in those sections also apply when determining whether the employer has shown under the first prong of the affirmative defense that it acted reasonably to prevent and correct the harassment alleged by the complainant.

Federal EEO law does not specify particular steps an employer must take to establish that it exercised reasonable care to prevent and correct harassment; instead, as discussed below, the employer will satisfy its obligations if, as a whole, its efforts are reasonable. 268 In assessing whether the employer has taken adequate steps, the inquiry typically begins by identifying the policies and practices an employer has instituted to prevent harassment and to respond to complaints of harassment. These steps usually consist of promulgating a policy against harassment, establishing a process for addressing harassment complaints, providing training to ensure employees understand their rights and responsibilities, and monitoring the workplace to ensure adherence to the employer’s policy. [269]

For an anti-harassment policy to be effective, it should generally have the following features:

• the policy defines what conduct is prohibited;
• the policy is widely disseminated; 270
• the policy is comprehensible to workers, 271 including those who the employer has reason to believe might have barriers to comprehension, such as employees with limited literacy skills or limited proficiency in English; 272
• the policy requires that supervisors report harassment when they are aware of it; 273
• the policy offers multiple avenues for reporting harassment, thereby allowing employees to contact someone other than their harassers; 274
• the policy clearly identifies accessible [275] points of contact to whom reports of harassment should be made and includes contact information; 276 and
• the policy explains the employer’s complaint process, including the process’s anti-retaliation and confidentiality protections.

For a complaint process to be effective, it should generally have the following features:

• the process provides for prompt and effective investigations and corrective action; [277]
• the process provides adequate confidentiality protections; 278 and
• the process provides adequate anti-retaliation protections. 279

For training to be effective, it should generally have the following features: 280

• it explains the employer’s anti-harassment policy and complaint process, including any alternative dispute resolution process, and confidentiality and anti-retaliation protections;
• it describes and provides examples of prohibited conduct under the policy;
• it provides information about employees’ rights if they experience, observe, become aware of, or report conduct that they believe may be prohibited;
• it provides supervisors and managers with information about how to prevent, identify, stop, report, and correct harassment, such as actions that can be taken to minimize the risk of harassment, and with clear instructions for addressing and reporting harassment that they observe, that is reported to them, or that they otherwise become aware of;
• it is tailored to the workplace and workforce;
• it is provided on a regular basis to all employees; and
• it is provided in a clear, easy-to-understand style and format. 281

However, even the best anti-harassment policy, complaint procedure, and training will not necessarily establish that the employer has exercised reasonable care to prevent harassment—the employer must also implement these elements effectively. 282 Thus, evidence that an employer has a comprehensive anti-harassment policy and complaint procedure will be insufficient standing alone to establish the first prong of the defense if the employer fails to implement these policies and procedures or to appropriately train employees. 283 Similarly, the first prong of the defense would not be established if evidence shows that the employer adopted or administered the policy in bad faith or that the policy was otherwise defective or dysfunctional. 284 Considerations that may be relevant to determining whether an employer unreasonably failed to prevent harassment are discussed in detail at section IV.C.3.a, below.

Likewise, the existence of an adequate anti-harassment policy, complaint procedure, and training is not dispositive of the issue of whether an employer exercised reasonable care to correct harassing behavior of which it knew or should have known. 285 For example, if a supervisor witnesses harassment by a subordinate, the supervisor’s knowledge of the harassment is imputed to the employer, and the duty to take corrective action will be triggered. 286 If the employer fails to exercise reasonable care to correct the harassing behavior, it will be unable to satisfy prong one of the Faragher-Ellerth defense, regardless of any policy, complaint procedure, or training. The duty to exercise reasonable care to correct harassment for which an employer had notice is discussed in detail at section IV.C.3.b, below .

Example 64: Employer Liable Because It Failed to Exercise Reasonable Care in Responding to Harassment—Employee Reported to a Supervisor. Aisha, who works as a cashier in a fast-food restaurant, was sexually harassed by one of her supervisors, Pax, an assistant manager. Aisha initially responded to Pax’s sexual advances and other sexual conduct by telling him that she was not interested and that his conduct made her uncomfortable. Pax’s conduct persisted, however, so Aisha spoke to the restaurant’s other assistant manager, Mallory. Like Pax, Mallory was designated as Aisha’s direct supervisor. The employer has an anti-harassment policy, which it distributes to all employees. The policy states that all supervisors are required to report and address potentially harassing conduct when they become aware of such conduct. Mallory, however, did not report Pax’s conduct or take any action because she felt Aisha was being overly sensitive. Pax continued to sexually harass Aisha, and a few weeks after speaking with Mallory, Aisha contacted the Human Resources Director. The following day, the employer placed Pax on paid administrative leave, and a week later, after concluding its investigation of Aisha’s allegations, the employer terminated Pax. The employer contends that it took reasonable corrective action by promptly responding to Aisha’s complaint to Human Resources. However, because Mallory was one of Aisha’s supervisors, and was therefore responsible for reporting and addressing potential harassment, the employer cannot establish the affirmative defense, having failed to act reasonably to address the harassment after Aisha spoke with Mallory.

Example 65: Employer Liable Because It Failed to Exercise Reasonable Care in Responding to Harassment—Supervisor Witnessed Harassment. Claudia works as an overnight stocker in the housewares department of a big box store. Her employer has an anti-harassment policy. The policy is, on its face, effective: for example, it describes harassment; provides multiple avenues for reporting harassment, including a 1-800 number operated by a third-party vendor; and contains an anti-retaliation provision. The policy is distributed to all employees at the time of their hire and can be accessed any time via computer terminals that all employees can use. Further, the employer ensures that all employees receive annual anti-harassment training that reminds them of the policy, including their rights and obligations under it.

Claudia is directly supervised by Dustin, the housewares department manager. On an almost nightly basis, Dustin likes to “play a game” in which he hides between store aisles and jumps out with his penis exposed to Claudia. Ravi, who manages the employer’s produce section, has witnessed Dustin expose his penis to Claudia on a few occasions. Ravi once admonished Dustin for being a “child” and told him “acting like that will lead to you getting fired,” but took no further action to address the harassment. Claudia was embarrassed by the harassment and was afraid that complaining would jeopardize her job, so she never reported the harassment, either to the employer or the 1-800 number.

Under these facts, the employer cannot establish the affirmative defense. While the employer appears to have acted reasonably in its efforts to prevent harassment by adopting a comprehensive and effective anti-harassment policy and providing training, it did not act reasonably to correct harassment that it knew about through Ravi’s direct observation.

ii. Second Prong of the Affirmative Defense: Employee’s Failure to Take Advantage of Preventive or Corrective Opportunities

The second prong of the Faragher-Ellerth affirmative defense requires the employer to show that the complainant “unreasonably failed to take advantage of any preventive or corrective opportunities provided by the employer or to avoid harm otherwise.” 287 If an employer has exercised reasonable care, it will not be liable if the complainant could have avoided all harm from unlawful harassment but unreasonably failed to do so. 288 In addition, if the employee unreasonably delayed complaining and an earlier complaint could have avoided some but not all of the harm from the harassment, then the employer might be able to use the affirmative defense to reduce damages, even if it could not eliminate liability altogether. [289]

Example 66: Employer Limits Damages by Establishing Affirmative Defense. Nina was subjected to a hostile work environment based on national origin harassment by her supervisor, Samantha. The evidence shows that the harassment began when Samantha used egregious epithets to refer to Nina’s national origin during an informal meeting Samantha held only with Nina and her coworkers, conduct that was sufficient standing alone to create a hostile work environment. The employer has an accessible anti-harassment policy, distributes the policy broadly, and holds anti-harassment training periodically. Although Samantha’s harassment of Nina continues, Nina does not complain until four months later, when she accepts a position with another employer. Then, Nina states she did not complain during her employment because she did not want to “rock the boat” or cause Samantha to be fired. The employer has established both elements of the affirmative defense with respect to the continuing harassment after the meeting because the employer acted reasonably to prevent and correct harassment and Nina could have avoided this harm by complaining promptly. However, the employer is liable for the hostile work environment created by Samantha’s initial use of the egregious epithets because Nina could not have avoided this harm by complaining earlier. As a result, Nina is entitled to damages for the hostile work environment arising from the informal meeting but not for any subsequent harassment.

Proof that the employee failed to use the employer’s complaint procedure will normally establish the second prong of the affirmative defense if following the procedure could have avoided the harm. 290 In some circumstances, however, there will be evidence of a reasonable explanation for an employee’s delay in complaining or failure to utilize the employer’s complaint process. 291 In addition, there will be instances when an employee’s use of mechanisms other than the employer’s official complaint process will be sufficient to demonstrate that the employee took reasonable steps to avoid harm from the harassment.

The reasonableness of an employee’s decision not to use the employer’s complaint procedure, or timing in doing so, depends on the particular circumstances and information available to the employee at that time . 292 An employee should not necessarily be expected to complain to management immediately after the first or second incident of relatively minor harassment. An employee might reasonably ignore a small number of minor incidents, hoping that the harassment will stop without resorting to the complaint process. [293] The employee also may choose to tell the harasser directly to stop the harassment and then wait to see if the harasser stops before complaining to management. If the harassment persists or worsens, however, then further delay in complaining might be unreasonable.

Even if the employee uses the employer’s official complaint process, the employer may still be able to establish the second prong of the Faragher - Ellerth affirmative defense where the employee failed to act reasonably in using the process. If, for example, the complainant unreasonably failed to cooperate in the investigation, the complaint by itself would not constitute a reasonable effort to avoid harm. 294

               a) Reasonable Delay in Complaining or in Failing to Use the Employer’s Complaint Procedure

There may be reasonable explanations for an employee’s delay in complaining or failure to utilize the employer’s complaint process. 295 For example:

• Employer-created obstacles to filing complaints : An employee’s failure to use the employer’s complaint procedure could be reasonable if that failure was based on employer-created obstacles to filing complaints. For example, if the process entailed undue expense by the employee, [296] inaccessible points of contact for making complaints, [297] or intimidating or burdensome requirements, failure to use the process could be reasonable.
• Ineffective complaint mechanism : As a general matter, an employee’s subjective belief that reporting harassment will be futile, without more, will not constitute a reasonable basis for failing to take advantage of preventive or corrective opportunities provided by an employer. 298 However, an employee’s failure to use the employer’s complaint procedure would be reasonable if that failure was based on a reasonable belief that the complaint process was ineffective. For example, an employee might have a reasonable belief that the complaint process would be ineffective if the persons designated to receive complaints were all close friends of the harasser. [299] A failure to complain also might be reasonable if the complainant was aware of instances in which the employer had failed to take appropriate corrective action in response to prior complaints filed by the complainant or by coworkers. [300]
• Risk of retaliation : A generalized fear of retaliation, standing alone, generally will not constitute a reasonable basis for failing to take advantage of preventive or corrective opportunities provided by an employer. 301 However, an employee’s failure to use the employer’s complaint procedure would be reasonable if the employee reasonably feared retaliation as a result of complaining about harassment. [302] An employer’s complaint procedure should provide assurances that complainants will not be subjected to retaliation. Even in the face of such assurances, however, an employee might reasonably fear retaliation in some instances. For example, if the harasser threatened the employee with reprisal for complaining, then the employee’s decision not to report or to delay reporting the harasser would likely be reasonable. 303 Similarly, an employee’s failure to complain could be reasonable if the employee or another employee had previously been subjected to retaliation for complaining about harassment. [304] By contrast, because it may not be possible for an employer to completely eliminate all unpleasantness that an employee may experience in reporting harassment, a failure to report or delay in reporting will not be considered reasonable if based merely on concerns about ordinary discomfort or embarrassment. 305

These examples are not exclusive, and there may be other reasonable explanations for why an employee fails to report, or delays in reporting, harassment. For instance, an employee’s delay in reporting might be reasonable if linked to psychological trauma resulting from the underlying harassment. 306

               b) Reasonable Efforts to Avoid Harm Other than by Using the Employer’s Complaint Process

Even if an employee failed to use the employer’s complaint process, the employer will not be able to establish the Faragher-Ellerth affirmative defense if the employee took other reasonable steps to avoid harm from the harassment. A promptly filed union grievance while the harassment is ongoing, for example, could qualify as a reasonable effort to avoid harm. [307] Similarly, a temporary employee who is harassed at the client’s workplace generally would be free to report the harassment to either the employment agency or the client, reasonably expecting that the entity she notified would act to correct the problem. [308]

3. Non-Supervisory Employees (E.g., Coworkers) and Non-Employees—Negligence [309]

An employer is liable for a hostile work environment created by non-supervisory employees or by non-employees if it was negligent because:

• it unreasonably failed to prevent the harassment; OR
• it failed to take reasonable corrective action in response to harassment about which it knew or should have known.

Although the negligence standard is principally applied in cases involving harassment by a non-supervisory employee or non-employee, it also can be applied in cases of harassment by a supervisor or an alter ego/proxy. [310]

An employer is liable for a hostile work environment created by non-supervisory employees or non-employees where the employer was negligent by failing to act reasonably to prevent the unlawful harassment from occurring. [311] Although the relevant considerations will vary from case to case, some of the considerations may include:

• 1) Adequacy of the employer’s anti-harassment policy, complaint procedures, and training: As with the first prong of the Faragher-Ellerth affirmative defense (which only applies to unlawful harassment by a supervisor), assessing negligence on the part of an employer starts with whether the employer had an adequate anti-harassment policy, complaint procedure, and training program to ensure employees understand their rights and responsibilities pursuant to the policy. [312] The elements described in section IV.C.2.b.i, above, with regard to an effective policy and complaint procedure, apply here as well.
• 2) Nature and degree of authority, if any, that the alleged harasser exercised over the complainant: [313] Employers have a heightened responsibility to protect employees against harassment by other employees whom they have “armed with authority” [314] even if the other employees are not “supervisors.” [315]
• 3) Adequacy of the employer’s efforts to monitor the workplace , [316] such as by training supervisors and other appropriate officials on how to recognize potential harassment and by requiring them to report or address harassment that they either are aware of or reasonably should have known about.
• 4) Adequacy of the employer’s steps to minimize known or obvious risks of harassment , such as harassment by inmates incarcerated in a maximum-security prison; [317] in workspaces that are isolated, decentralized, lack a diverse workforce, or rely on customer service or client satisfaction; and against employees who are vulnerable, young, do not conform to workplace norms based on societal stereotypes, or who are assigned to complete monotonous or low-intensity tasks. 318

Example 67: Employer Unreasonably Failed to Prevent Unlawful Harassment. Willie, a man with intellectual and developmental disabilities, works for a janitorial company. The other members of Willie’s cleaning crew also are individuals with intellectual and/or developmental disabilities, except for the team lead, Bobby. (As a team lead, Bobby is responsible for ensuring all crew members have access to cleaning supplies and the spaces that the crew will be cleaning; Bobby does not have the ability to hire, fire, demote, promote, transfer, or discipline Willie or any other crew member.) At the time of hire, each new employee is required to watch a one-hour anti-harassment training video focusing on legal standards and is required to sign a training acknowledgment form without the opportunity to ask questions. Although Willie watched the module, he did not understand it because of his disabilities. No one from the company discussed the training with Willie. While at worksites, Bobby frequently berates Willie and other team members by calling them “dummy” or “ret*rd,” and asks demeaning questions, such as “did your mom drop you on your head when you were a baby?” Bobby also mimics the crew members’ disabilities. No one else from the janitorial company ever comes to Willie’s worksites to check in with him or the other crew members, and because Willie and the other crew members, other than Bobby, do not understand how the anti-harassment policy works, they do not complain and are subjected to continued disability-based harassment. Based on these facts, the employer has not acted reasonably to prevent Willie and the other crew members from being subjected to unlawful harassment.

Example 68: Employer Acted Reasonably to Prevent Unlawful Harassment. Danielle, a pulmonary and respiratory care nurse at a large hospital system, is responsible for caring for patients recovering from respiratory conditions at the hospital, such as Lewis, a patient recovering from pneumonia. At the time Lewis was admitted, his son stated, “I hope your staff is prepared because dad has some ‘old-timey’ attitudes toward women and wandering hands.” The hospital is understaffed, which often requires Danielle and other nurses to work in isolated conditions, such as by entering patients’ rooms alone. Given Lewis’s son’s statement and knowing that employees who work in isolated conditions are at a higher risk of harassment, when Danielle is assigned to care for Lewis, her supervisor warns her about Lewis’s potential conduct; offers to reassign Lewis to another nurse, if one is available; and, if another nurse is not available or if Danielle wants to keep the assignment, offers to assign another staff member to accompany Danielle into Lewis’s room. Based on these facts, the employer has acted reasonably to prevent Danielle from being subjected to unlawful harassment.

Even if an employer acted reasonably to prevent unlawful harassment by coworkers or non-employees, it is still liable for a hostile work environment if it was negligent because it did not act reasonably to correct harassment about which it knew or should have known. [319]

• An employer has notice of harassment if an individual responsible for reporting or taking corrective action with respect to the harassment is aware of it or if such an individual reasonably should have known about the harassment.

Corrective Action

• Once an employer has actual or constructive notice of potential harassment, it is required to take reasonable corrective action to prevent the conduct from continuing.

The first element that triggers an employer’s duty to take reasonable corrective action in response to harassment is having notice of the harassment. [320]

An employer has actual notice of harassment if an individual responsible for reporting or taking corrective action with respect to the harassment is aware of it. [321] Thus, if harassment is observed by or reported to any individual responsible for reporting harassment to management or taking corrective action, then the employer has actual notice of the harassment. For example, an employer has actual notice of harassment if an employee with a general duty to respond to harassment under the employer’s anti-harassment policy, such as the EEO Director, a manager, or a supervisor who does not directly supervise either the harasser or the target of the harassment but who does have a duty to report harassment, is aware of the harassment. [322] In addition, an employer has notice if someone qualifying as the employer’s proxy or alter ego, such as an owner or high-ranking officer, has knowledge of the harassment. [323]

Example 69: Employer Had Notice of Harassment. Lawrence, a Black man in his sixties, was employed as a laborer in a distribution yard where he was subjected to race- and age-based harassment by coworkers. Although Lawrence’s employer contends that it was never notified of the harassment until Lawrence made a complaint after being fired for misconduct, a “yard lead,” who was responsible for instructing and organizing teams of yard workers, acknowledges that Lawrence complained to him about the harassment before Lawrence was fired. According to the employer’s policy, the yard lead was expected to report problems to the yard manager, who had authority to take disciplinary action against employees. Because the yard lead was responsible for referring Lawrence’s complaint to an appropriate official authorized to take corrective action, the employer had actual notice of the alleged harassment. [324]

A complaint can be made by a third party, such as a friend, relative, or coworker, and need not be made by the target of the harassment. For example, if an employee witnesses a coworker being subjected to racial epithets by a person at work, and that employee reports it to the appropriate personnel in Human Resources, the employer is on notice of potentially harassing behavior. Similarly, even if no one complains, the employer still has notice if someone responsible for correcting or reporting harassment becomes aware of the harassment, such as by personally witnessing it. [325]

The employer’s duty to take corrective action is triggered if the notice it has received is sufficient to make a reasonable employer aware of the possibility that an individual is being subjected to harassment on a protected basis. While no “magic words” are required to initiate a harassment complaint, the complaint (or other vehicle for notice) must identify potentially harassing conduct in some way. 326 Therefore, a complaint simply that a coworker’s conduct was “rude” and “aggravating” might not provide sufficient notice depending on the circumstances. Conversely, evidence that an employee had engaged in “unwanted touching” of another employee likely would be sufficient to alert the employer of a reasonable probability that the second employee was being sexually harassed and that it should investigate the conduct and take corrective action. [327]

Example 70: Employer Had Notice of Harassment. Susan was subjected to sex-based harassment by her coworker, Jim. Although Susan’s employer contends that it did not have notice of the conduct, evidence shows that Susan requested a schedule change when she was scheduled to work alone with Jim, and that Susan’s coworkers told her supervisor, Barb, that Susan wanted to avoid working with Jim. Also, Jim told Barb that he may have “done something or said something that [he] should not have to Susan.” When Barb asked Susan about working with Jim, Susan became teary and red and said, “I can’t talk about it.” Barb responded by saying, “That’s good because I don’t want to know what happened.” Under the circumstances, Barb had enough information to suspect that Jim was harassing Susan. As Susan’s supervisor, Barb had the responsibility to take corrective action, if she had the authority, or to notify another official who did have the authority to take corrective action. [328]

Although an employer cannot be found liable for conduct that does not violate federal EEO law, the duty to take corrective action may be triggered by notice of harassing conduct that has not yet risen to the level of a hostile work environment, but may reasonably be expected to lead to a hostile work environment if appropriate corrective action is not taken. [329]

Notice of harassing conduct directed at one employee might serve as notice not only of the harasser’s potential for further harassment of the same employee but also of the harasser’s potential to harass others. Factors in assessing the relevance of the employer’s knowledge of prior harassment can include the “extent and seriousness of the earlier harassment and the similarity and nearness in time to the later harassment.” [330]

An employer has constructive notice of harassing conduct if, under the circumstances presented, a reasonable employer should know about the conduct. [331] Most commonly, an employer is deemed to have constructive notice if harassing conduct is severe, widespread, or pervasive so that individuals responsible for taking action with respect to the harassment reasonably should know about it. [332] An employer also may be deemed to have constructive notice of harassment if it did not have reasonable procedures for reporting harassment. [333]

Example 71: Employer Had Constructive Notice of Harassment. Joe, who is Mexican American, works as an automotive parts salesman for a car dealership. Joe’s job requires him to frequently enter the dealership’s service department. The service department is managed by Aseel, who is onsite in the service department all day when he supervises a team of five mechanics. At least once per day while Joe is in the service department, a mechanic, Tanner, yells at Joe across the room, calling him “wetback” and “sp*c,” among other epithets. The other mechanics sometimes talk amongst themselves about how Tanner’s conduct toward Joe never stops in the service department, that Tanner seems to enjoy having an audience, and how they are surprised that Tanner’s conduct continues even after their employer provided anti-harassment training to all of the employees working at the dealership. Based on this evidence, the employer had constructive notice of the hostile work environment because Service Manager Aseel knew or should have known about Tanner’s conduct. [334]

ii. Reasonable Corrective Action

Once an employer has notice of potentially harassing conduct, it is responsible for taking reasonable corrective action to prevent the conduct from continuing. This includes conducting a prompt and adequate investigation and taking appropriate action based on the findings of that investigation.

               a) Prompt and Adequate Investigation

An investigation is prompt [335] if it is conducted reasonably soon after the employee complains or the employer otherwise has notice of possible harassment. Clearly, an employer that opens an investigation into a complaint one day after it is made has acted promptly. 336 By contrast, an employer that waits two months to open an investigation, absent any mitigating facts, very likely has not acted promptly. 337 In many instances, what is “reasonably soon” is fact-sensitive and depends on such considerations as the nature and severity of the alleged harassment and the reasons for delay. 338 For example, when faced with allegations of physical touching, an employer that, without explanation, does nothing for two weeks likely has not acted promptly. 339

An investigation is adequate if it is sufficiently thorough to “arrive at a reasonably fair estimate of truth.” [340] The investigation need not entail a trial-type investigation, but it should be conducted by an impartial party and seek information about the conduct from all parties involved. The alleged harasser therefore should not have supervisory authority over the individual who conducts the investigation and should not have any direct or indirect control over the investigation. If there are conflicting versions of relevant events, it may be necessary for the investigator to make credibility assessments to determine whether the alleged harassment in fact occurred. [341] Accordingly, whoever conducts the investigation should be well-trained in the skills required for interviewing witnesses and evaluating credibility.

Example 72: Employer Failed to Conduct Adequate Investigation. George, a construction worker, repeatedly complains to the superintendent that he is being harassed because of his disability by Phil, a coworker. After about two weeks, the superintendent asks a friend of his to conduct an investigation, even though this individual is not familiar with EEO law and has no experience conducting harassment investigations. The investigator meets with George and Phil individually for about ten minutes, and asks only a few perfunctory questions. From these interviews, the investigator issues a single-page memorandum concluding, without further explanation, that there is no basis for finding that George was harassed. Based on these facts, the employer has not conducted an adequate investigation. 342

Upon completing its investigation, the employer should inform the complainant and alleged harasser of its determination and any corrective action that it will be taking, subject to applicable privacy laws. [343]

Employers should retain records of all harassment complaints and investigations. [344] These records can help employers identify patterns of harassment, which can be useful for improving preventive measures, including training. These records also can be relevant to credibility assessments and disciplinary measures.

In some cases, it may be necessary, given the seriousness of the alleged harassment, for the employer to take intermediate steps to address the situation while it investigates the complaint. [345] Examples of such measures include making scheduling changes to avoid contact between the parties; temporarily transferring the alleged harasser; or placing the alleged harasser on non-disciplinary leave with pay pending the conclusion of the investigation. As a rule, an employer should make every reasonable effort to minimize the burden or negative consequences to an employee who complains of harassment, both during and after the employer’s investigation. [346]

Corrective action that leaves the complainant worse off could constitute unlawful retaliation. 347 The employer should take measures to ensure that retaliation does not occur. For example, when management investigates a complaint of harassment, the official who interviews the parties and witnesses should remind these individuals about the prohibition against retaliation. Management also should scrutinize employment decisions affecting the complainant and witnesses during and after the investigation to ensure that such decisions are not based on retaliation.

               b) Appropriate Corrective Action

To avoid liability, an employer must take corrective action that is “reasonably calculated to prevent further harassment” under the particular circumstances at that time. [348] Corrective action should be designed to stop the harassment and prevent it from continuing. [349] The reasonableness of the employer’s corrective action depends on the particular facts and circumstances at the time the action is taken. [350]

Considerations that will be relevant in evaluating the reasonableness of an employer’s corrective action include the following:

• 1) Proportionality of the corrective action : Corrective action should be proportionate to the seriousness of the offense. [351] If the harassment was comparatively minor and involved an individual with no prior history of similar misconduct, then counseling and an oral warning might be all that is necessary. In other circumstances, separating the harasser and the complainant may be adequate. On the other hand, if the harassment was severe or persistent despite prior corrective action, then suspension or discharge of the harasser may be necessary. [352]
• 2) Authority granted harasser : Employers have a heightened responsibility to protect employees against abuse of official power. To that end, employers must take steps to prevent employees who have been granted authority over others from using it to further harassment, even if that authority is insufficient to establish vicarious liability. [353] Thus, the nature and degree of the harasser’s authority should be considered in evaluating the adequacy of corrective action. [354]
• 3) Whether harassment stops : After taking corrective action, an employer should monitor the situation to ensure that the harassment has stopped. Whether the harassment stopped is a key factor indicating whether the corrective action was appropriate. However, the continuation of harassment despite an employer’s corrective action does not necessarily mean that the corrective action was inadequate. [355] For example, if an employer takes appropriate proportionate corrective action against a first-time harasser who engaged in a mildly offensive series of jokes and innuendos, yet the same employee subsequently engages in further harassment, then the employer may not be liable if it also responded appropriately to the subsequent misconduct by taking further corrective action appropriate to the pattern of harassment. On the other hand, an employer who takes no action in response to a complaint of harassment may not be shielded from liability by the fact that the harassment “fortuitously stops.” [356]
• 4) Effect on complainant : An employee who in good faith complains of harassment should ideally face no burden because of the corrective action the employer takes to stop harassment or prevent it from occurring; for example, corrective action generally should not involve involuntarily transferring the complaining employee while leaving the alleged harasser in place. [357] However, the employer may place some burdens on the complaining employee as part of the corrective action it imposes on the harasser if it makes every reasonable effort to minimize those burdens or adverse consequences. [358]
• 5) Options available to the employer : [359] Employers have an “arsenal of incentives and sanctions” available to them to address harassment. [360] However, an employer’s options for corrective actions may vary depending on who engages in the conduct and where it occurs, among other considerations.

6) The extent to which the harassment was substantiated : Where an employer conducts a thorough investigation but is unable to determine with sufficient confidence that the alleged harassment occurred, its response may be more limited. An employer is not required to impose discipline if, after a thorough investigation, it concludes that the alleged harassment did not occur, or if it has inconclusive findings. [361] Nonetheless, if the employer is unable to determine whether the alleged harassment occurred, the employer may wish to consider preventive measures, such as counseling, training, monitoring, or issuing general workforce reminders about the employer’s anti-harassment policy. 362

Example 73: Employer failed to take reasonable corrective action. Malak, a server at a sports bar, is visibly pregnant. Every Sunday, Kevin and Troy spend the afternoon at the bar cheering on their favorite teams, and they usually sit in Malak’s section. They repeatedly ask if they can rub her belly “for luck” before games, and berate her when she refuses, calling her a “mean mama.” They also frequently make beeping sounds and yell, “Careful! Wide load!” when Malak serves other tables. In addition, they ask if she plans to breastfeed and offer to “help out with practice sessions.” Sven, a manager, overhears Kevin and Troy, laughs, and says halfheartedly, “C’mon guys, give her a break.” They ignore him and continue to comment about Malak’s pregnancy. Malak complains to Sven, who throws up his hands and says, “Hey, I did what I could. What else do you want me to do? If I barred everyone who made a few dumb comments when they were drunk, we’d have no customers at all.” Based on these facts, the employer has failed to take reasonable corrective action to address Kevin and Troy’s pregnancy-based harassment of Malak.

Example 74: Employer took reasonable corrective action. Same facts as above, but instead of laughing and making a halfhearted request that Kevin and Troy stop harassing Malak, Sven tells Kevin and Troy that they must stop making comments about Malak’s pregnancy and warns them that they will be barred from the establishment if they persist. Sven tells Malak to notify him or another manager immediately if the comments continue. Sven also asks Malak if she would like Kevin and Troy reseated in another section, but she declines, and he asks other managers to keep an eye on Kevin and Troy to make sure the two men do not continue to harass Malak. Three weeks later, Kevin and Troy resume making offensive pregnancy-related comments to Malak. Before Malak can notify Sven, another manager does so, and Sven promptly gives Kevin and Troy their checks, directs them to pay their bills, and notifies them they are no longer welcome at the bar. Based on these facts, the employer has taken adequate corrective action to address Kevin and Troy’s pregnancy-based harassment of Malak.

• 7) Special considerations when balancing anti-harassment and accommodation obligations with respect to religious expression : 363 Title VII requires that employers accommodate employees’ sincerely held religious beliefs, practices, and observances unless doing so would impose an undue hardship. 364 Employers also are responsible for protecting workers against unlawful harassment, including harassment motivated by religion or created by religious expression. To address these dual obligations, an employer should accommodate an employee’s sincerely held religious practice of engaging in religious expression in the workplace, unless doing so would create, or reasonably threatens to create, a hostile work environment. Thus, while an employer may need to provide a religious accommodation that disrupts “[c]omplete harmony in the workplace,” 365 the employer should take corrective action to address religious expression that creates, or threatens to create, a hostile work environment, or otherwise would result in undue hardship. [366] As with other forms of harassment, an employer should take corrective action before the conduct becomes sufficiently severe or pervasive to create a hostile work environment.

Corrective action in response to a harassment complaint must be taken without regard to the complainant’s protected characteristics. Thus, employers should follow consistent processes to investigate harassment claims, and to determine what corrective action, if any, is appropriate. For example, it would violate Title VII if an employer assumed that a male employee accused of sexual harassment by a female coworker had engaged in the alleged conduct based on stereotypes about the “propensity of men to harass sexually their female colleagues” 367 and therefore fired him.

In some circumstances, an employee may report harassment but ask that the employer keep the matter confidential and take no action. Although it may be reasonable in some circumstances to honor the employee’s request when the conduct is relatively mild, it may not be reasonable to do so in all circumstances, 368 including, for instance, if it appears likely that the harassment was severe [369] or if employees other than the complainant are vulnerable. [370] One mechanism to help minimize such conflicts could be for the employer to set up an informational phone line or website that allows employees to ask questions or share concerns about harassment anonymously. [371] In such circumstances, the employer also may be required to take general corrective action to reduce the likelihood of harassment in the future, such as recirculating its anti-harassment policy.

               c) Assessing the Liability of Joint Employers

If an individual has been assigned by an employment agency to work for a client, then both the agency and the client may jointly employ the individual during the period when the individual works for the client. [372] If a worker is jointly employed by two or more employers, then each of the worker’s employers is responsible for taking corrective action to address any alleged harassment about which it has notice. [373] An employer has the same responsibility to prevent and correct harassment of non-direct hire employees as harassment of permanent employees. 374 Therefore, under such circumstances, if the worker complains about harassment to both the client and the employment agency, then both entities would be responsible for taking corrective action. 375 Joint employers are not required to take duplicative corrective action, but each has an obligation to respond to potential harassment, either independently or in cooperation. Once the employee complains to either entity, that entity is responsible to take reasonable steps within its control to address the harassment and to work with the other entity, if necessary, to resolve the situation. 376

As with an employer, an employment agency is responsible for taking reasonable corrective action within its own control. This is true regardless of whether the employment agency’s client is also a joint employer. Corrective action may include, but is not limited to: ensuring that the client is aware of the alleged harassment; insisting that the client conduct an investigation and take appropriate corrective measures on its own; working with the client to jointly conduct an investigation and/or identify appropriate corrective measures; following up and monitoring to ensure that corrective measures have been taken; and providing the worker with the opportunity to take another job assignment at the same pay rate, if such an assignment is available and the worker chooses to do so.

Example 75: Temporary Agency Takes Adequate Corrective Action, But Client Does Not. Yousef is a Muslim software engineer of Arab American heritage. He is assigned by an employment agency to work for a technology company on a software development project. The evidence establishes that the agency and technology company are joint employers of Yousef. Soon after Yousef starts working, Eddie, one of his coworkers, begins making frequent comments about his religion and ethnicity. For example, Eddie says that Middle Easterners and Muslims “prefer to solve problems with their guns and bombs, rather than their brains.” He also says that “the Middle East’s number one export is terrorism,” and recommends that Yousef’s work be reviewed carefully “to make sure he’s not embedding bugs on behalf of terrorists.” Yousef tells Eddie to stop, but he refuses. Yousef complains to the employment agency, which promptly notifies the technology company and requests that it take corrective action. The technology company refuses to take any action, explaining that Eddie is one of its most experienced programmers, that his assistance is crucial to the project’s satisfactory completion, and that his reputation in the tech industry has attracted numerous prestigious clients to the company. The employment agency promptly reassigns Yousef to a different client at the same pay rate. 377 The employment agency also declines to assign other workers to the technology company until the company takes appropriate corrective action to address Eddie’s conduct. Based on these facts, the agency took appropriate corrective action as to Yousef, while the technology company did not.

Like other forms of discrimination, harassment can be systemic, subjecting multiple individuals to a similar form of discrimination. If harassment is systemic, then the harassing conduct could subject many, or possibly all, of the employees of a protected group to the same circumstances. For example, evidence might show that the Black employees working on a particular shift were subjected to, or otherwise knew about, the same racial epithets, racial imagery, and other offensive race-based conduct. [378] In such a situation, evidence of widespread race-based harassment could be used to establish that Black employees working on that shift were individually subjected to an objectively hostile work environment. Similarly, evidence that a group of individuals with intellectual disabilities had been physically abused, financially exploited, and subjected to verbal abuse including frequently being called “ret*rded,” “dumb ass,” and “stupid” 379 could establish a disability-based hostile work environment for all of the impacted individuals.

Example 76: Same Evidence of Racial Harassment Establishes Objectively Hostile Work Environment for Multiple Employees. A group of five Black correctional officers, who are the only Black officers on their shift, experienced racial mistreatment and jokes, including aggressive treatment by dog handlers stationed at the entrance and racial references and epithets, such as the n-word, “back of the bus,” and “the hood.” Much of the conduct occurred in a communal setting, such as the cafeteria, in which supervisors participated or laughed at the conduct without objecting. This conduct occurred regularly, despite the Black officers’ repeated objections. Although none of the Black officers were personally subjected to every harassing incident, they each were subjected to some of the similar conduct because the harassers treated them as a cohesive group. Further, each became aware of harassment experienced by the others, even if they were not present when every discriminatory comment was made. Based on these facts, given the totality of circumstances, each of the Black officers was subjected to an objectively hostile work environment based on race. [380]

In some situations involving systemic harassment, the evidence may establish that the employer engaged in a “pattern or practice” of discrimination, meaning that the employer’s “standard operating procedure” was to engage in or tolerate harassment creating a hostile work environment. [381] An allegation of a pattern or practice of harassment focuses on the “landscape of the total work environment, rather than the subjective experiences of each individual claimant” [382] —in other words, whether the work environment, as a whole, was hostile. [383] For instance, in one case, the court concluded that evidence of widespread abuse, including physical assault, threats of deportation, denial of medical care, and limiting contact with the “outside world,” was sufficient to establish that it was the employer’s standard operating procedure to subject Thai nationals employed on the defendant’s farms to a hostile work environment. [384]

An employer’s efforts to prevent or correct systemic harassment must be adequate to fully address the nature and scope of the harassment the employer knows (or reasonably should know) was or is occurring. For example, an employer cannot simply correct the harassment as to a particular subset of individuals known to be affected. Moreover, if there have been frequent individual incidents of harassment, then the employer must take steps to determine whether that conduct reflects the existence of a wider problem requiring a systemic response, such as developing comprehensive company-wide procedures. [385]

Example 77: Evidence Establishes Pattern or Practice of Sex Harassment. Zoe alleges that she has been subjected to ongoing sex-based harassment at the soap manufacturing plant where she works. An investigation reveals that female employees throughout the same plant have been frequently subjected to physically invasive conduct by male coworkers, including the touching of women’s breasts and buttocks; that women have been targeted by repeated sexual comments and conduct; and that there are open displays of sexually offensive materials throughout the plant, including pornographic magazines and calendars. The investigation further reveals that the employer either knew or should have known about the widespread sexual harassment. In particular, much of the harassment occurred openly in public places, such as the display of pornography, and many incidents, such as sexual comments, occurred in the presence of supervisors who were required by the employer’s anti-harassment policy to report sexual harassment to the Human Resources Department. Finally, although management has taken some corrective action in isolated cases, there is no evidence that management has taken steps to determine whether the harassment is part of a systemic problem requiring appropriate plant-wide corrective action. Based on these facts, the employer has subjected female employees at the plant to a pattern or practice of sexual harassment. [386]

A. EEOC Harassment Home Page: https://www.eeoc.gov/harassment

B. EEOC Sexual Harassment Home Page: https://www.eeoc.gov/sexual-harassment

C. EEOC Select Task Force on the Study of Harassment in the Workplace: https://www.eeoc.gov/eeoc-select-task-force-study-harassment-workplace

D. Chai R. Feldblum & Victoria A. Lipnic, EEOC, Select Task Force on the Study of Harassment in the Workplace, Report of Co-Chairs Chai R. Feldblum & Victoria A. Lipnic (2016), https://www.eeoc.gov/june-2016-report-co-chairs-select-task-force-study-harassment-workplace

E. Promising Practices for Preventing Harassment: https://www.eeoc.gov/laws/guidance/promising-practices-preventing-harassment

F. Promising Practices for Preventing Harassment in the Federal Sector: https://www.eeoc.gov/federal-sector/reports/promising-practices-preventing-harassment-federal-sector

G. EEOC Retaliation Home Page: https://www.eeoc.gov/retaliation

H. Enforcement Guidance on Retaliation and Related Issues: https://www.eeoc.gov/laws/guidance/enforcement-guidance-retaliation-and-related-issues

Addendum Pursuant to 29 C.F.R. § 1695.6(c) on EEOC Responses to Major Comments Received on the Proposed Enforcement Guidance on Harassment in the Workplace

The Equal Employment Opportunity Commission (Commission or EEOC) published a Notice in the Federal Register on October 2, 2023, inviting the public to submit comments on its proposed Enforcement Guidance on Harassment in the Workplace and including a hyperlink to the federal website with the proposed guidance. [387]   The comment period ended on November 2, 2023.  During this period, the EEOC received over 37,000 comments from private individuals, organizations, and legislators.  The majority of comments from private individuals were identical form (standardized) comments or slightly altered form comments.  The comments from organizations addressed a range of issues and some requested that the Commission add additional hypothetical examples.

The Commission carefully considered all the comments it received in the process of revising the draft and preparing the final guidance.  The major issues raised in the comments and the Commission’s responses are listed, summarized, and addressed below.

EEOC Authority

Eeoc authority to address harassment based on gender identity related to sex-segregated facilities and pronouns.

Comment: Some commenters contended that the Commission exceeded its statutory authority under Title VII of the Civil Rights Act of 1964 (Title VII) because, they asserted, the proposed guidance exceeded the scope of Title VII as interpreted by the Supreme Court in Bostock v. Clayton County , 590 U.S. 644 (2020).  These commenters stated that the decision in Bostock was limited in scope and did not address, among other things, sex-segregated bathrooms.

Response:  

The proposed guidance did not attempt to—nor does the final guidance attempt to—impose new legal obligations on employers with respect to any aspect of workplace harassment law, including gender identity discrimination.  Nor does the guidance exceed the scope of the Supreme Court’s decision in Bostock.  

Section 703(a)(1) of Title VII makes it unlawful “to fail or refuse to hire or to discharge any individual, or otherwise to discriminate against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual’s . . . sex[.]”  At least since 1986, the Supreme Court has been unequivocal that “[t]he phrase ‘terms, conditions, or privileges of employment’ evinces a congressional intent to strike at the entire spectrum of disparate treatment of men and women in employment,” including discriminatory harassment.   Meritor Sav. Bank, FSB v. Vinson , 477 U.S. 57, 64 (1986).

The Court in Bostock explained that “it is impossible to discriminate against a person for being homosexual or transgender without discriminating against that individual based on sex,” and therefore held that discharging an employee because of sexual orientation or gender identity is unlawful sex discrimination that violates section 703(a)(1).  See Bostock v. Clayton Cnty. , 590 U.S. 644, 660, 683 (2020).  As a form of sex discrimination, discrimination on the basis of sexual orientation or gender identity therefore violates section 703(a)(1) on the same terms as any other form of sex discrimination, including failing or refusing to hire, or otherwise discriminating against an individual with respect to compensation, terms, conditions, or privileges of employment.  Any other interpretation would be inconsistent with the statutory text and with Bostock , and would introduce an inconsistent and textually unsupported asymmetry under which an employee could not be terminated because of their sexual orientation or gender identity but could be harassed or otherwise discriminated against in the terms and conditions of employment based on those same characteristics.

For these reasons, as stated in the final guidance, federal courts interpreting Bostock have readily found that unlawful workplace harassment based on sexual orientation or gender identity that constructively changes the terms and conditions of employment under section 703(a)(1) constitutes sex discrimination.  See the cases cited in footnote 37 of the final Enforcement Guidance on Harassment in the Workplace.

Bostock stated that it did not address “bathrooms, locker rooms, or anything else of the kind.” 590 U.S. at 681.  Nothing in the guidance suggests that Bostock addressed those issues.  Because the EEOC is statutorily required to investigate all private sector Title VII charges of discrimination presented to it in the administrative process, and also to decide administrative appeals by federal employees raising Title VII claims, the EEOC must sometimes take a position on whether an alleged type of conduct violates Title VII even in the absence of binding Supreme Court precedent. In fulfilling its statutory duties, the EEOC considers applicable legal authority and arguments advanced by affected parties when determining whether a violation has occurred in the context of a particular charge or federal sector EEO appeal.  As noted in the final guidance, by the time Bostock  was decided the Commission had been presented with the federal sector administrative appeal in Lusardi v. Department of the Army , EEOC Appeal No. 0120133395, 2015 WL 1607756 (Apr. 1, 2015), involving a transgender employee.  On the facts presented in that administrative appeal, the Commission decided that Title VII’s prohibition on sex discrimination requires employers to provide transgender employees access to sex-segregated facilities consistent with their gender identity.  See also Doe v. Triangle Doughnuts, LLC , 472 F. Supp. 3d 115, 135 (E.D. Pa. 2020) (listing allegations that plaintiff was prevented from using a bathroom that was consistent with her gender identity as among the allegations that supported her Title VII and ADA hostile work environment claims).  The Commission also decided in  Lusardi that the repeated and intentional use of pronouns inconsistent with an employee’s gender identity could contribute to a hostile work environment.  As described in footnote 42 of the guidance, even before  Bostock , courts have considered evidence of intentional and repeated misgendering, viewed in light of the totality of circumstances, as potentially supportive of a hostile work environment claim.

Substance of the Guidance

Adding more hypothetical examples to the final guidance that address harassment in more contexts.

Comment: Numerous commenters urged the Commission to add additional examples illustrating how the EEO laws apply to potential harassment in a variety of contexts.

Response: The final guidance has many examples involving a broad range of circumstances.  The new examples provide more comprehensive guidance on the EEOC’s views as to the application of federal EEO laws to potential harassment scenarios.  They also highlight how harassment can affect various vulnerable populations and underserved communities, including teen workers and survivors of gender-based violence.  Discrimination against vulnerable populations and underserved communities is among the Commission’s subject-matter priorities for fiscal years 2024-2028.  See EEOC, Strategic Enforcement Plan Fiscal Years 2024-2028,  https://www.eeoc.gov/strategic-enforcement-plan-fiscal-years-2024-2028 (last visited Apr. 12, 2024).

Ultimately, however, because of the fact-specific nature of these cases, the guidance necessarily cannot be exhaustive, and the guidance is not intended to illustrate every possible factual situation that might involve unlawful harassment.  Rather, the guidance presents the overarching legal standards that are applied to particular circumstances in evaluating whether the EEO laws have been violated and the employer is liable.  The examples are intended to be merely a small representative sample to illustrate how the legal principles apply in certain circumstances.

Totality-of-Circumstances Test

Comment: Multiple commenters requested that the Commission clarify its discussion of how to determine whether harassment is actionable based on the totality of circumstances. Some contended that the proposed guidance places too much emphasis on severity and pervasiveness and fails to properly incorporate those considerations into the broader examination of the totality of circumstances.

Response: The final guidance has been restructured, and the discussion of objective hostility in section III.B has been revised to more clearly illustrate how to evaluate whether harassment creates a hostile work environment based on the totality of circumstances.  As the Supreme Court has explained, harassment based on a protected trait violates EEO law when it is sufficiently severe or pervasive to alter the conditions of employment by creating a hostile work environment.  Harris v. Forklift Sys., Inc. , 510 U.S. 17, 21 (1993).  The Court has further explained that whether the work environment is hostile “can be determined only by looking at all the circumstances.”  Id. at 23.  Consistent with this Supreme Court precedent, the Commission has retained separate discussions of severity and pervasiveness in the final guidance but further illustrated how they are evaluated, along with other considerations, in the context of the totality of the circumstances.

Interplay Between Statutory Harassment Prohibitions and Other Rights

Free speech and religion-based rights.

Many of the individual comments addressed free speech and religion-based rights issues.  Some addressed only free speech, and many addressed both free speech and religion-based rights.  However, because the constitutional analysis of free speech and religion-based rights is different, the Commission addresses them separately. 

Free Speech

Comment: Numerous commenters, including the majority of private individuals who submitted form comments, contended that the draft guidance unconstitutionally infringes on the free-speech rights of employees or employers either by restricting their speech on certain issues, including abortion, or by requiring that they engage in certain speech, such as requiring the use of pronouns based on another individual’s gender identity.  Some commenters further requested clarification on the application of federal EEO laws to speech and expressive conduct that occurs outside the workplace, such as on personal social media accounts.

Response: The Commission fully recognizes the importance of protecting free speech and has added to the guidance specific language about the potential interaction between statutory harassment prohibitions and other legal doctrines, including the U.S. Constitution, at section I.A and footnote 363. The interplay between free speech protections and statutory harassment prohibitions in particular matters can be highly fact-specific, and the Commission will carefully consider these issues as presented on a case-by-case basis.  A detailed discussion of free speech principles, however, is beyond the scope of this final guidance.

Some commenters also expressed concern that, as they understood the guidance, any workplace discussion of religious perspectives on certain issues, such as abortion or gender identity, would be unlawful harassment.  That interpretation is not correct and is not the Commission’s intent.  As discussed in the final guidance, whether conduct constitutes unlawful harassment depends on all the circumstances and is only unlawful under federal EEO law if it creates a hostile work environment.  To help clarify that potentially offensive conduct based on a protected characteristic does not necessarily constitute unlawful harassment, the final guidance includes language in section I.B and at the beginning of section II to emphasize that conduct is not necessarily unlawful merely because it is based on a protected characteristic and that conduct also must alter a term, condition, or privilege of employment, typically by creating a hostile work environment.

Finally, the Commission revised the draft to respond to requests that it clarify its position with respect to conduct that occurs outside the workplace.  Section III.C.2.c of the final guidance explains that conduct that occurs outside the workplace, including on social media accounts, and that does not target the employer or its employees and is not brought into the workplace generally will not have an impact on the workplace and therefore will not contribute to a hostile work environment. 

Religion-Based Rights

Religious accommodation under title vii.

Comment: Many commenters urged the EEOC to address the interplay between an employer’s Title VII obligation to provide a reasonable accommodation for an employee’s sincerely held religious beliefs, practices, and observances and its obligation to prevent and correct unlawful harassment in the workplace.  Most of these comments focused on religious expression with regard to pronouns and cited the decision in Meriwether v. Hartop , 992 F.3d 492 (6th Cir. 2020), which held that a public university violated a professor’s constitutional right to free speech by refusing to accommodate his request not to refer to a transgender student using pronouns consistent with the student’s gender identity, a practice that conflicted with his religious beliefs.

Response: Section IV.C.3.b.ii(b)(7) of the guidance addresses the interaction between statutory harassment prohibitions and Title VII religious accommodation requirements with respect to expression in the workplace.  The Commission revised this section of the guidance by providing more detail about the Title VII precedent as well as new examples.  The Commission also added language about the Supreme Court’s recent decision in Groff v. DeJoy , 600 U.S. 447 (2023), which clarified the undue hardship standard in Title VII religious accommodation cases. 

The Commission acknowledges that in some cases, the application of the EEO statutes enforced by the EEOC may implicate other rights or requirements including those under the United States Constitution, other federal laws such as the Religious Freedom Restoration Act (RFRA), or sections 702(a) and 703(e)(2) of Title VII.  When the Commission is presented with individualized facts in an EEOC administrative harassment charge, the agency works with great care to analyze the interaction of Title VII harassment law and the rights to free speech and free exercise of religion.  For further information, see the relevant sections of EEOC’s Compliance Manual Section on Religious Discrimination.  EEOC, Compliance Manual Section 12: Religious Discrimination , No. 915.063, at   §§ 12-I.C, 12-III.D, and Addendum (2021),  https://www.eeoc.gov/laws/guidance/section-12-religious-discrimination .

Similarly, the Commission fully recognizes the importance of the constitutional right to free speech, which was analyzed by the court in Meriwether v. Hartop, supra , a case cited by many commenters.  While the plaintiff in that case did not plead a cause of action under Title VII, if a charge is filed with the EEOC raising similar issues, the EEOC will give the decision appropriate consideration.  The Commission carefully considers the facts presented in EEOC charges alleging a failure to provide a reasonable accommodation for a religious belief, practice, or observance, and takes into consideration the employer, employment context, and other relevant facts.

Although cited in a few comments, the Commission did not cite or address in the final guidance the decision in Kluge v. Brownsburg Community School Corp. , 64 F.4th 861 (7th Cir. 2023).  Kluge involves a Title VII religious accommodation claim related to pronoun and first-name use, but the Seventh Circuit vacated and remanded the case after the Supreme Court issued Groff .  2023 WL 4842324 (7th Cir. July 28, 2023). Once the courts have completed adjudication of Kluge , the Commission will give the final decision appropriate consideration when considering charges alleging these issues.

To assist employers with potential defenses, including religious defenses, in the context of individual charge investigations, the Commission is enhancing its administrative procedures and webpages.   Specifically, the Commission will revise materials accompanying the Notice of Charge of Discrimination letter and related webpages to identify how employers can raise defenses in response to a charge.  This information will be public and viewable by any employer with questions or concerns about how to raise a defense, including a religious defense, in the event that one of its employees files a charge of discrimination.  The Commission also will update the Respondent Portal to encourage an employer to raise in its position statement (or as soon as possible after a charge is filed) any factual or legal defenses it believes apply, including defenses based on religion.

As appropriate, the Commission will resolve a charge based on the information submitted in support of asserted defenses, including religious defenses, in order to minimize the burden on the employer and the charging party.  Regardless of whether the Commission agrees with the employer’s asserted defenses, those defenses are entitled to de novo review by a court in any subsequent litigation.

Interplay Between Statutory Harassment Prohibitions and the U.S. Constitution, Sections 702(a) and 703(e)(2) of Title VII, and RFRA

Comment: Numerous commenters expressed concern about the potential interaction of statutory prohibitions against discrimination, including unlawful harassment, with the religion-based rights of employees and employers, and they urged the Commission to clarify the interplay between statutory harassment prohibitions and religion-based rights protected under the U.S. Constitution, Title VII (the religious organization exceptions), and the Religious Freedom Restoration Act (RFRA).

Response: The Commission recognizes the importance of protecting religion-based rights.  Because the interplay between religion-based rights and statutory harassment prohibitions can be highly fact-specific, the Commission will consider these issues as presented on a case-by-case basis.  The Commission added language at section I.A. and footnote 363, which highlight the potential interaction between statutory harassment prohibitions and other legal doctrines, including the U.S. Constitution, RFRA, and sections 702(a) and 703(e)(2) of Title VII.  The Commission also added more discussion, legal citations, and examples to section IV.C.3.b.ii(b)(7), which addresses balancing antiharassment and accommodation obligations with respect to religious expression.  Readers seeking to learn more about the interplay between statutory harassment prohibitions and religion-based rights should consult relevant portions of the EEOC’s Compliance Manual Section on Religious Discrimination.  See  EEOC, Compliance Manual Section 12: Religious Discrimination , No. 915.063, at   §§ 12-I.C, 12-III.D, and Addendum (2021),  https://www.eeoc.gov/laws/guidance/section-12-religious-discrimination .

Finally, as noted above, to assist employers seeking to assert potential defenses, including religious defenses, in the context of individual charge investigations, the Commission is enhancing its administrative procedures and providing information to employers and respondents to charges.

National Labor Relations Act

Comment: Multiple commenters requested the Commission clarify the interplay between an employers’ obligations to address workplace harassment under federal employment discrimination laws and to comply with the National Labor Relations Act.

Response: A discussion of the interaction of EEO laws with the National Labor Relations Act (NLRA), 29 U.S.C. § 157 et seq., is beyond the scope of this guidance, which is focused only on statutes enforced by the Commission.  The National Labor Relations Board (NLRB) has the sole authority to enforce the NLRA.  The EEOC consults with the NLRB’s Office of General Counsel as needed to help ensure workable application of the statutory protections for both workers’ civil rights and the NLRA.  

1 477 U.S. 57 (1986).

2 See EEOC, Enforcement and Litigation Statistics , https://www.eeoc.gov/data/enforcement-and-litigation-statistics-0 (last visited Apr. 25, 2024).

3 See, e.g ., EEOC v. Sandia Transp., LLC , No. 1:23-cv-00274 (D.N.M. consent decree entered Mar. 14, 2024) (settlement on behalf of four women subjected to sex harassment that included the owner repeatedly using various epithets and stating he hated “f*ckin’ dealing with women”); EEOC v. Schuff Steel Co. , No. 2:22-cv-01653 (D. Ariz. consent decree entered Dec. 19, 2023) (settlement on behalf of a class of aggrieved Black and Latino employees alleging race- and national-origin-based harassment, including use of the N-word; calling Latino employees “beaners;” and ridiculing Latino employees who did not speak English well); EEOC v. UFP Ranson, LLC , No. 3:21-CV-00149 (N.D.W. Va. consent decree entered Sept. 28, 2023) (settlement of lawsuit alleging harassment based on race and religion on behalf of a Black Muslim worker who was repeatedly called race- and religion-based epithets; told that members of the Ku Klux Klan worked at the facility; had objects thrown at him while he was praying; was physically intimidated and shoulder-checked; and was required to perform tasks by means that were unnecessarily onerous); EEOC v. Chipotle Servs., LLC , No. 2:22-cv-00279 (W.D. Wash. consent decree entered Sept. 14, 2023) (settlement on behalf of three female employees, including a teenager, subjected to a sexually hostile work environment that included touching, unwelcome sexual comments, and requests for sex); EEOC v. T.M.F Mooresville, LLC , No. 5:21-cv-00128 (W.D.N.C. consent decree entered Aug. 24, 2022) (settlement on behalf of a class of White housekeeping employees allegedly subjected to harassment based on race, which included use of racially derogatory terms such as “white trash”); EEOC v. CCC Grp., 1:20-cv-00610 (N.D.N.Y. consent decree entered Aug. 9, 2021) (settlement on behalf of seven Black employees at an industrial construction site allegedly subjected to repeated racist slurs, displays of nooses, and comments about lynchings by White supervisors and coworkers); EEOC v. Nabors Corp. Servs., Inc. , No. 5:16-cv-00758 (W.D. Tex. consent decree entered Nov. 12, 2019) (settlement on behalf of nine Black employees and one White employee based on alleged racial harassment, which included employees being addressed as “n****r” and being referred to as the “colored crew,” and retaliation, among other allegations).

4 42 U.S.C. § 2000e-5 (Title VII); 29 U.S.C. § 626 (Age Discrimination in Employment Act (ADEA)); 42 U.S.C. § 12117(a) (Americans with Disabilities Act (ADA)); 42 U.S.C. § 2000ff-6(a) (Genetic Information Nondiscrimination Act (GINA)). This guidance addresses harassment claims under provisions of the federal EEO laws that prohibit discrimination by employers, including section 703(a)(1) of Title VII, 42 U.S.C. § 2000e-2(a)(1) (private sector and state and local government) and section 717 of Title VII, 42 U.S.C. § 2000e-16(a) (federal agencies). It does not address potential claims of unlawful harassment under provisions that prohibit discrimination by other entities covered under Title VII, such as employment agencies and labor organizations, including sections 703(b) and 703(c) of Title VII, 42 U.S.C. §§ 2000e-2(b) and 2000e-2(c). See, e.g. , Dixon v. Int’l Bhd. of Police Officers , 504 F.3d 73, 84-85 (1st Cir. 2007) (upholding a jury verdict finding a union liable for sexual harassment that occurred during a union-sponsored bus trip).

The standards discussed here under EEOC-enforced laws will not necessarily apply to claims alleging unlawful harassment under other federal laws or under state or local laws.

5 We note, for instance, that a discussion of the interaction of EEO laws with the National Labor Relations Act (NLRA), 29 U.S.C. § 157 et seq., is beyond the scope of this guidance, which is focused only on statutes enforced by the Commission. The National Labor Relations Board (NLRB) has the sole authority to enforce the NLRA. The EEOC consults with the NLRB’s Office of General Counsel as needed to help ensure workable application of the statutory protections for both workers’ civil rights and the NLRA.

6 See 29 C.F.R. § 1695.2(c)(7)(i).

7 For further information, see the relevant sections of EEOC’s Compliance Manual Section on Religious Discrimination. EEOC, Compliance Manual Section 12: Religious Discrimination , No. 915.063, §§ 12-I.C, 12-III.D, and Addendum (2021), https://www.eeoc.gov/laws/guidance/section-12-religious-discrimination .

8 See section VI, infra (providing links to EEOC harassment-related resources).

9 See, e.g. , Laurent-Workman v. Wormuth , 54 F.4th 201, 212 (4th Cir. 2022) (holding that the plaintiff established at least a plausible claim of race-based harassment where a White coworker’s statements that she “could not understand African Americans because they cannot speak properly communicated racial enmity by summoning an odious trope about African American speech patterns”); Gates v. Bd. of Educ. , 916 F.3d 631, 633-34, 640-41 (7th Cir. 2019) (concluding that a reasonable jury could find that the plaintiff was subjected to a racially hostile work environment based on three incidents with his supervisor, specifically that his supervisor made a joke in which he referred to the plaintiff as a “sh*t-sniffing n****r,” threatened to write up the plaintiff’s “black ass,” and stated he was “tired of you people” and again referred to the plaintiff as “n****r”); Ellis v. Houston , 742 F.3d 307, 314, 320-21 (8th Cir. 2014) (reversing a grant of summary judgment for the defendants on the plaintiffs’ racial harassment claims under 42 U.S.C. §§ 1981 and 1983 where there was evidence of a widespread pattern of racial harassment that included racial stereotyping, such as referring to the African American plaintiffs as “the gang” or “the back of the bus” and addressing them with comments about the “hood” or fried chicken and watermelon); Boone v. Old Colony Young Men’s Christian Ass’n , No. 13-13131, 2015 WL 7253676, at *3 (D. Mass. Nov. 17, 2015) (concluding that a reasonable jury could find that a reference to a pornographic movie with a title based on racial stereotypes constituted race-based harassment); Chambers v. Walmart Stores, Inc. , No. 1:14CV996, 2015 WL 4479100, at *1, *3 (M.D.N.C. July 22, 2015) (recommending denial of a motion to dismiss a racial harassment claim alleging that a manager used racial slurs and negative racial stereotypes, such as referring to Black people as “Blackie” and using the term “ghetto” to describe the appearance of the store), report and recommendation adopted , 2015 WL 5147056 (Sept, 1, 2015).

10 See EEOC, Compliance Manual Section 15: Race & Color Discrimination § 15-II (2006), https://www.eeoc.gov/laws/guidance/section-15-race-and-color-discrimination#II ; see also, e.g. , Ellis , 742 F.3d at 314 (noting “[o]ffensive comments . . . about the qualities of black hair and black hairstyles” when describing a pattern of race-based harassment); Fuller v. Fiber Glass Sys., LP , 618 F.3d 858, 864 (8th Cir. 2010) (concluding that the evidence was sufficient to establish that the plaintiff’s work environment was hostile where, among other things, the plaintiff alleged that she was admonished for answering the phones because “customers weren’t used to hearing a black voice”).

11 See, e.g. , § II.B.3, infra (explaining that harassment based on stereotypes about a protected group need not be motivated by animus or hostility toward that group).

12 See EEOC, Compliance Manual Section 15: Race & Color Discrimination § 15-III (2006), https://www.eeoc.gov/laws/guidance/section-15-race-and-color-discrimination#III ; see also, e.g. , EEOC v. Pioneer Hotel, Inc ., No. 2:11-CV-01588, 2013 WL 3716447, at *3 (D. Nev. July 15, 2013) (denying a motion to dismiss a claim of harassment against a class of Latino and/or dark-skinned employees based on national origin and/or skin color); Wiltz v. Christus Hosp. St. Mary , No. 1:09-CV-925, 2011 WL 1576932, at *8 (E.D. Tex. Mar. 10, 2011) (stating harassment is based on color when the complained-of conduct has a color-related character or purpose and collecting cases supporting the same); Brack v. Shoney’s, Inc. , 249 F. Supp. 2d 938, 953-55 (W.D. Tenn. 2003) (holding there was sufficient evidence of color-based harassment to survive the employer’s summary judgment motion where the plaintiff’s supervisor called him “little black sheep” and expressed a preference for a “fair skinned” manager, among other things); cf. Etienne v. Spanish Lake Truck & Casino Plaza, LLC , 778 F.3d 473, 477 (5th Cir. 2015) (vacating summary judgment for the employer regarding its failure to promote the plaintiff to a managerial position where the plaintiff offered evidence that she was qualified for the position and provided direct evidence that she was not considered for the position because of her skin color); Arrocha v. City Univ. of N.Y., No. CV-02-1868, 2004 WL 594981, at *6 (E.D.N.Y. Feb. 9, 2004) (concluding that the plaintiff had alleged color, not race, discrimination where the plaintiff claimed light-skinned Hispanics were favored over dark-skinned Hispanics); Walker v. Sec’y of the Treasury , 713 F. Supp. 403, 405-08 (N.D. Ga. 1989) (concluding that the plaintiff stated a claim for relief under Title VII where she alleged that her supervisor, a Black woman with dark skin, terminated the plaintiff, also a Black woman, because of her light skin color), aff’d without opinion , 953 F.2d 650 (11th Cir. 1992).

13 This example is adapted from the facts in EEOC v. Rugo Stone, LLC , No. 1:11-cv-915 (E.D. Va. consent decree entered Mar. 6, 2012).

14 See, e.g. , Kang v. U. Lim Am., Inc. , 296 F.3d 810, 817 (9th Cir. 2002) (concluding that the plaintiff could establish that he was harassed based on his national origin, Korean, where his supervisor allegedly subjected Korean workers to abuse based on their failure to “live up” to the stereotype that Korean workers are “better than the rest”).

15 See 29 C.F.R. § 1606.1 (“The Commission defines national origin discrimination broadly as including, but not limited to, the denial of equal employment opportunity . . . because an individual has the physical, cultural or linguistic characteristics of a national origin group.”); EEOC, Enforcement Guidance on National Origin Discrimination § II.B (2016)https://www.eeoc.gov/laws/guidance/national-origin-guidance.cfm#_Toc451518801 (stating that national origin discrimination includes discrimination based on physical, linguistic, or cultural traits); see also, e.g. , Diaz v. Swift-Eckrich, Inc. , 318 F.3d 796, 799-801 (8th Cir. 2003) (holding that evidence of frequent harassment, including taunts about a Hispanic employee’s accent and statements that “Hispanics should be cleaning” and that “Hispanics are ‘stupid,’” was sufficient to show that an employee was subjected to pervasive harassment that created a hostile work environment); Gonzales v. Eagle Leasing Co. , No. 3:13-CV-1565, 2015 WL 4886489, at *5 (D. Conn. Aug. 14, 2015) (holding that a reasonable jury could find that the plaintiff was subjected to a hostile work environment based on race, national origin, and ethnicity where the harassment included derogatory comments about traditional Cuban food); Garcia v. Garland Indep. Sch. Dist., No. 3:11-CV-502, 2013 WL 5299264, at *4-6 (N.D. Tex. Sept. 20, 2013) (declining to grant summary judgment where a hostile work environment claim included an allegation that the defendant’s employees mocked the plaintiff’s mispronunciation of words and ridiculed her for lack of English fluency); Syed v. YWCA of Hanover , 906 F. Supp. 2d 345, 355-56 (M.D. Pa. 2012) (holding that a fact finder could infer that harassment was based on race or national origin where the plaintiff’s supervisor criticized her “awful” Pakistani-styled dress, called her a “brown b*tch,” suggested she did not know how to open a door due to her national origin, and told her she needed to learn to drive because “we don’t ride camel[s] here”).

16 Title VII defines “religion” to include “all aspects of religious observance and practice, as well as belief.” 42 U.S.C. § 2000e(j). This term is broad and is not limited to traditional or organized religions. However, social, political, or economic philosophies, as well as mere personal preferences, are not religious beliefs protected by Title VII. EEOC, Compliance Manual Section 12: Religious Discrimination , No. 915.063, § 12-I.A.1 (2021), https://www.eeoc.gov/laws/guidance/section-12-religious-discrimination#h_9593682596821610748647076 .

17 See EEOC v. Townley Eng’g & Mfg. Co. , 859 F.2d 610, 613-17 (9th Cir. 1988) (applying Title VII to religious discrimination claim based on atheism); Young v. Sw. Sav. & Loan Ass’n , 509 F.2d 140, 143-44 (5th Cir. 1975) (same); Mathis v. Christian Heating & Air Conditioning, Inc. , 158 F. Supp. 3d 317, 329 (“Under Title VII, atheists are entitled to the exact same protection as members of other religions.”) (E.D. Pa. 2016); see also Reed v. Great Lakes Cos. , 330 F.3d 931, 934 (7th Cir. 2003) (noting that firing someone for being an atheist violates Title VII’s prohibition against religious discrimination); Scott v. Montgomery Cnty. Sch. Bd. , 963 F. Supp. 2d 544, 559 n.11 (W.D. Va. 2013) (“Title VII’s definition of ‘religion’ includes ‘all aspects of religious observance and practice, as well as belief . . . .’ and . . . protects persons who are not members of organized religious groups as well as atheists.” (internal citation omitted)).

18 See, e.g. , Dediol v. Best Chevrolet, Inc. , 655 F.3d 435, 443-44 (5th Cir. 2011) (holding that a fact finder could conclude that the plaintiff was subjected to unlawful religious harassment, which included disparaging comments about his religious beliefs); EEOC v. Sunbelt Rentals, Inc. , 521 F.3d 306, 314 (4th Cir. 2008) (reversing summary judgment for the employer on a religious harassment claim that included evidence that the employee was harassed, in part, because of his religious headwear).

19 See, e.g. , Sunbelt Rentals, Inc. , 521 F.3d at 316-18 (reversing summary judgment for the employer where there was evidence that a Muslim employee was subjected to persistent religious harassment, which included repeatedly referring to the employee as “Taliban” or “towel head,” challenging the employee’s allegiance to the United States, and stereotyping Muslims as terrorists).

20 See, e.g. , Abramson v. William Paterson Coll. of N.J. , 260 F.3d 265, 279 (3d Cir. 2001) (holding that a reasonable jury could find that hostility directed toward an Orthodox Jewish college professor regarding her insistence that she not work during the Sabbath constituted harassment based on religion); Ibraheem v. Wackenhut Servs., Inc. , 29 F. Supp. 3d 196, 203, 214 (E.D.N.Y. 2014) (holding that a reasonable jury could conclude that the plaintiff was subjected to unlawful religious harassment after he received an exception to the employer’s no-beard policy as a reasonable accommodation when, for example, supervisors asked the plaintiff to see the letter documenting his religion and disciplined him for various infractions shortly thereafter).

For more information on religious discrimination, see https://www.eeoc.gov/religious-discrimination (last visited Apr. 24, 2024) (discussing religious discrimination and providing links to other EEOC resources).

21 For a detailed discussion and additional examples of Title VII’s prohibition against harassment because of religion, see section 12-III.B of EEOC’s Compliance Manual Section on Religious Discrimination. EEOC, Compliance Manual Section 12: Religious Discrimination , No. 915.063, §12-III.B (2021), https://www.eeoc.gov/laws/guidance/section-12-religious-discrimination#h_39980494324601610748877628 .

22 See Winspear v. Cmty. Dev., Inc. , 574 F.3d 604, 608 (8th Cir. 2009) (remanding hostile work environment claim to the district court in order to address summary judgment motion in the first instance where the district court had noted that the plaintiff “‘may have raised a genuine issue of material fact as to whether [] repeated comments about [the plaintiff’s] brother suffering in Hell and . . . needing to find God constituted a hostile work environment’” but also had erroneously analyzed the hostile work environment claim as a constructive discharge claim).

23 See EEOC v. Townley Eng’g & Mfg. Co. , 859 F.2d 610, 620-21 (9th Cir. 1988) (“Protecting an employee’s right to be free from forced observance of the religion of his employer is at the heart of Title VII’s prohibition against religious discrimination.”); see also Garcimonde-Fisher v. Area203 Mktg., LLC , 105 F. Supp. 3d 825, 840 (E.D. Tenn. 2015) (“Title VII forbids employers from forcing employees to make [the] choice [“My religion or my job?”] whether overtly or covertly. Hostile work environment claims prevent employers from creating conditions that are inhospitable to any but those who share their beliefs.”); EEOC v. United Health Programs of Am., Inc. , No. 1:14-cv-3673, 2020 WL 1083771, at *5-11 (E.D.N.Y. Mar. 6, 2020) (affirming jury verdict concerning a hostile work environment based on religion where employees were forced to participate in “new age” religious activities at work against their wishes).

24 See Tillery v. ATSI, Inc. , 242 F. Supp. 2d 1051, 1058 (N.D. Ala. 2003) (summary judgment to employer denied where the owner “repeatedly subjected plaintiff to lectures about her prospects for salvation during working hours, made highly personal inquiries into her private life (e.g., the legitimacy of her children, and whether a prior marriage had been terminated by divorce versus the doctrine of annulment sanctioned by the Catholic Church), and ‘strongly suggested [she] talk with God’”); see also EEOC v. Preferred Mgmt. Corp. , 216 F. Supp. 2d 763, 837 (S.D. Ind. 2002) (discussing how employers’ “expectations” regarding alleged voluntary participation in religious activities can amount to coercion).

25 Meritor Sav. Bank, FSB v. Vinson , 477 U.S. 57, 65 (1986) (stating that sex-based harassment includes “[u]nwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature” (alteration in original) (quoting 29 C.F.R. § 1604.11(a))); see also, e.g. , Hatley v. Hilton Hotels Corp. , 308 F.3d 473, 475 (5th Cir. 2002) (holding that the district court erred in granting judgment as a matter of law for the employer where sex-based harassment consisted of repeated touching, vulgar comments, propositions, and physical aggression).

26 Harassment based on sex is often referred to interchangeably as sex-based harassment or sexual harassment, without regard to whether the harassment at issue involves what this document refers to as “sexual conduct.”

27 See, e.g. , Waldo v. Consumers Energy Co. , 726 F.3d 802, 815 (6th Cir. 2013) (explaining that non-sexual conduct can be based on sex and therefore contribute to a sex-based hostile work environment); Rosario v. Dep’t of the Army , 607 F.3d 241, 248 (1st Cir. 2010) (stating that conduct that does not have sexual connotations can contribute to a sex-based hostile work environment).

28 See infra Example 35: Comparative Evidence Gives Rise to Inference that Harassment Is Based on a Protected Characteristic (providing an example of facially sex-neutral offensive conduct motivated by sex, such as bullying directed toward employees of one sex).

29 This document does not analyze application of the Pregnant Workers Fairness Act to harassment based on an employee’s request for, or receipt of, an accommodation.

30 See Walsh v. Nat’l Comput. Sys., Inc. , 332 F.3d 1150, 1160 (8th Cir. 2003) (upholding jury verdict finding the plaintiff was subjected to a hostile work environment based on pregnancy where the plaintiff’s supervisor made numerous derogatory comments about her pregnancy and required the plaintiff to provide advance notice and documentation of doctor’s appointments, even though the plaintiff’s coworkers were not required to provide such information for appointments); Fugarino v. Milling, Benson, Woodward LLP , No. 21-594, 2022 WL 6743191, at *3 (E.D. La. Oct. 11, 2022) (denying summary judgment to the employer on the plaintiff’s claim of pregnancy-based harassment alleging, among other things, that she was subjected to comments about the size of her breasts, the “shape and curves of her body” as an Italian pregnant woman, and how her “‘milk’ would come in” and make her breasts even larger); Young v. AlaTrade Foods, LLC , 2:18-CV-00455, 2019 WL 4245688, at *2 (N.D. Ala. Sept. 6, 2019) (denying summary judgment to the employer on the plaintiff’s sexual harassment claim alleging that she was subjected to conduct that included comments from the plaintiff’s supervisor who, upon learning she was pregnant, told her “he was upset because he did not want anyone else to have her,” “made sexual hand gestures with his smock in front of her and told her that she had ‘nice breasts’ that were ‘a nice size for sucking,’” said she had a “fine sexy ass,” touched her, whispered in her ear, touched/grazed her buttocks, and showed her pictures of himself partially undressed).

31 42 U.S.C. § 2000e(k) (“The terms ‘because of sex’ or ‘on the basis of sex’ include, but are not limited to, because of or on the basis of pregnancy, childbirth, or related medical conditions ....”).

32 See Hicks v. City of Tuscaloosa , 870 F.3d 1253, 1260 (11th Cir. 2017) (concluding that Title VII prohibits discrimination based on breastfeeding); EEOC v. Hous. Funding II, Ltd. , 717 F.3d 425, 430 (5th Cir. 2013) (holding that Title VII prohibits discharging an employee because she is lactating).

33 See EEOC, Enforcement Guidance on Pregnancy Discrimination and Related Issues § I.A.3.d (2015), https://www.eeoc.gov/laws/guidance/enforcement-guidance-pregnancy-discrimination-and-related-issues#IA3d (stating that Title VII prohibits discrimination against a woman because she uses contraceptives and citing cases).

34 See id. § I.A.4.c, https://www.eeoc.gov/laws/guidance/enforcement-guidance-pregnancy-discrimination-and-related-issues#IA4c ; see also, e.g. , Doe v. C.A.R.S. Prot. Plus, Inc. , 527 F.3d 358, 364 (3d Cir. 2008) (holding that Title VII prohibits discrimination against a female employee because she has had an abortion); Turic v. Holland Hosp., Inc. , 85 F.3d 1211, 1214 (6th Cir. 1996) (same). Title VII would similarly prohibit adverse employment actions against an employee based on her decision not to have an abortion. Velez v. Novartis Pharms. Corp ., 244 F.R.D. 243, 267 (S.D.N.Y. 2007) (concluding that a declaration by a female employee that she was encouraged by a manager to get an abortion was anecdotal evidence supporting a class claim of pregnancy discrimination).

35 See Zuckerman v. GW Acquisition LLC , No. 20-CV-8742, 2021 WL 4267815, at *2 (S.D.N.Y. Sept. 20, 2021) (denying the defendant’s motion for summary judgment where two owners made a series of offensive comments about the plaintiff’s decision to breastfeed and to pump breastmilk at the office, including one owner asking “‘if he could ‘have some milk in [his] coffee’ and whether [the plaintiff] could ‘just squirt it in there,’” and another owner “frequently yell[ing] ‘pump station’ or ‘pumper’ when he would pass the designated pumping area in the office”).

36 See Bostock v. Clayton Cnty. , 590 U.S. 644 (2020); Copeland v. Ga. Dep’t of Corr. , ___ F.4th ___, No. 22-13073, 2024 WL 1316677, at *5 (11th Cir. Mar. 28, 2024) (citing Bostock and stating that “discrimination against transgender individuals like [the plaintiff] is discrimination ‘because of sex’”); Sch. of the Ozarks, Inc. v. Biden , 41 F.4th 992, 995 (8th Cir. 2022) (“ Bostock held that the statute’s prohibition on employment discrimination ‘because of sex’ encompasses discrimination on the basis of sexual orientation and gender identity.”); Olivarez v. T-Mobile USA, Inc. , 997 F.3d 595, 598 (5th Cir. 2021) (“Under Bostock v. Clayton County , discrimination on the basis of sexual orientation or gender identity is a form of sex discrimination under Title VII.”).

In its decisions regarding federal employees’ EEO claims, the Commission has concluded that discrimination on the basis of sexual orientation or gender identity violates Title VII. See, e.g. , Lusardi v. Dep’t of the Army , EEOC Appeal No. 0120133395, 2015 WL 1607756, at *10-13 (Apr. 1, 2015) (finding that harassment violated section 717 of Title VII, which prohibits federal agencies from engaging in employment discrimination on the basis of sex, because the harassment was based on the plaintiff’s gender identity); Baldwin v. Dep’t of Transp. , EEOC Appeal No. 0120133080, 2015 WL 4397641, at *5, *10 (July 15, 2015) (concluding as a matter of law that sexual orientation is inherently “a ‘sex-based consideration,’” and that an allegation of discrimination based on sexual orientation is necessarily an allegation of sex discrimination under section 717 of Title VII).

37 Bostock itself concerned allegations of discriminatory discharge, but the Supreme Court’s reasoning in the decision about the nature of discrimination based on sex logically extends to claims of harassment that change the terms, conditions, or privileges of employment under section 703(a)(1) of Title VII. As a result, courts have readily found post- Bostock that claims of harassment based on one’s sexual orientation or gender identity are cognizable under Title VII. See, e.g. , Copeland , 2024 WL 1316677, at *5 (citing Bostock and stating that “a transgender man who was harassed about his gender after coming out at work” was subjected to ““discrimination ‘because of sex’”); Roberts v. Glenn Indus. Grp., Inc. , 998 F.3d 111, 121 (4th Cir. 2021) (“[T]he Supreme Court’s holding in Bostock makes clear that a plaintiff may prove that same-sex harassment is based on sex where the plaintiff was perceived as not conforming to traditional male stereotypes.”); Doe v. City of Det. , 3 F.4th 294, 300 n.1 (6th Cir. 2021) (stating that harassment on the basis of transgender identity is sex discrimination under Title VII because “it is impossible to discriminate against a person for being . . . transgender without discriminating against that individual based on sex”); Simmons v. Starved Rock Casework LLC , No. 20-CV-1684, 2021 WL 5359017, at *2 (E.D. Wis. Nov. 17, 2021) (finding that the plaintiff had stated a claim for relief by alleging a hostile work environment based on his heterosexual status); Boney v. Tex. A&M Univ. , No. 4:19-CV-2594, 2021 WL 3640714, at *4 n.5 (S.D. Tex. July 19, 2021) (“The Fifth Circuit has construed the Supreme Court’s recent decision in Bostock as holding that Title VII prohibits workplace discrimination based on homosexuality[; therefore] a plaintiff may establish a Title VII violation by showing a hostile work environment based on sexual orientation discrimination.” (citing Newbury v. City of Windcrest , 991 F.3d 672, 676-77 (5th Cir. 2021))); EEOC v. R.G. &. G.R. Harris Funeral Homes, Inc ., 884 F.3d 560, 571 (6th Cir. 2018) (Title VII covers both failure to conform to sex stereotypes and transgender or transitioning status), aff’d sub nom. Bostock v. Clayton Cnty. , 590 U.S. 644 (2020); Doe v. Triangle Doughnuts, LLC , 472 F. Supp. 3d 115, 129 (E.D. Pa. 2020) (“It naturally follows [from Bostock ] that discrimination based on gender stereotyping falls within Title VII’s prohibitions.”). In addition, in the context of federal sector cases, the Commission has concluded that sex-based harassment includes harassment based on sexual orientation or gender identity. See, e.g. , Lusardi , 2015 WL 1607756, at *10-13 (finding that harassment based on the plaintiff’s transgender status violates section 717); Baldwin , 2015 WL 4397641, at *7-8 (stating that discrimination, including harassment, that is based on sexual orientation violates section 717).

38 See, e.g. , Eller v. Prince George’s Cnty. Pub. Sch. , 580 F. Supp. 3d 154, 173 (D. Md. 2022) (concluding that a reasonable jury could find that the plaintiff was subjected to gender identity-based harassment that was objectively severe or pervasive, including derogatory terms referring to her transgender status); Brooks v. Temple Univ. Health Sys., Inc. , No. 21-1803, 2022 WL 1062981, at *12 (E.D. Pa. Apr. 8, 2022) (denying summary judgment to the employer on the plaintiff sex-based hostile work environment claim where the plaintiff alleged, among other things, that he was called a “f*ggot”).

39 See, e.g. , Roberts , 998 F. 3d at 121 (stating that alleged physical assaults may be part of a pattern of objectionable, sex-based discriminatory behavior that supports a hostile environment claim); Eller , 580 F. Supp. 3d at 173 (holding that a reasonable jury could find that alleged harassment, which included “multiple physical assaults, including one incident when [a transgender teacher] was shoved out of a door, and two incidents . . . when students who had used slurs about her transgender status stepped and pressed down hard on her foot,” was objectively severe or pervasive).

40 See, e.g. , Doe v. Arizona , No. CV-18-00348, 2019 WL 2929953, at *3 (D. Ariz. July 8, 2019) (denying summary judgment to the employer on the plaintiff’s sex-based harassment claim where the plaintiff, a corrections officer, presented evidence including that “supervisors regularly disregarded his requests to conceal his status for the purpose of protecting his safety, and repeatedly engaged in behavior that may be considered harassment by a jury”); Roberts v. Clark Cnty. Sch. Dist. , 215 F. Supp. 3d 1001, 1017 (D. Nev. 2016) (denying summary judgment to the employer on a school police officer’s sex-based harassment claim where the employee was “blindsided” by emails that the school district sent to every police department employee disclosing sensitive information about the plaintiff’s sexual identity and invited coworkers to ask questions about his transition).

41 See, e.g. , Brooks , 2022 WL 1062981, at *12 (stating that comments that included “being picked on for his feminine presentation” may be “severe enough to alter the conditions of one’s work environment”).

42 See Copeland , 2024 WL 1316677, at *5-9 (concluding that a reasonable jury could find that a male transgender corrections officer was subjected to a sex-based hostile work environment where, among other things, supervisors, coworkers, and inmates intentionally and repeatedly referred to him using feminine pronouns or called him “ma’am”). Courts—even prior to the Supreme Court’s Bostock decision—have viewed evidence of intentional misgendering of transgender persons as supportive of a hostile work environment claim under Title VII. See, e.g. , Houlb v. Saber Healthcare Grp. , No. 1:16CV02130, 2018 WL 1151566, at *2 (N.D. Ohio Mar. 2, 2018) (holding that the alleged misgendering, together with the other alleged offensive conduct, was sufficiently severe or pervasive to constitute a violation of Title VII for purposes of summary judgment); Tudor v. Se. Okla. State Univ. , No. CIV-15-324-C, 2017 WL 4849118, at *1 (W.D. Okla. Oct. 26, 2017) (same); Versace v. Starwood Hotels & Resorts Worldwide, Inc. , No. 6:14-cv-1003-Orl-31KRS, 2015 WL 12820072, at *7 (M.D. Fla. Dec. 3, 2015) (considering alleged misgendering to support the plaintiff’s hostile environment claim, but finding the alleged incidents to be insufficiently frequent or severe to constitute a violation); see also Triangle Doughnuts, LLC , 472 F. Supp. 3d at 129-30 (holding that the employee plausibly alleged sex-based harassment based in part on being regularly misgendered); Parker v. Strawser Constr., Inc. , 307 F. Supp. 3d 744, 758 (S.D. Ohio 2018) (same).

In federal sector EEO appeals, the Commission has concluded that misgendering and denial of access to a bathroom consistent with the individual’s gender identity may constitute sex discrimination in violation of Title VII. See, e.g. , Jameson v. U.S. Postal Serv. , EEOC Appeal No. 0120130992, 2013 WL 2368729, at *2 (May 21, 2013) (stating that repeated, intentional misuse of the name or pronoun with which a transgender employee identifies may constitute sex-based harassment); Lusardi , 2015 WL 1607756, at *10-13 (holding that a supervisor’s repeated and intentional use of the incorrect name and pronouns for the complainant, in addition to the agency’s refusal to allow the complainant to use the restroom consistent with her gender identity, were actions sufficiently severe or pervasive to subject the complainant to a hostile work environment based on her sex).

43 See, e.g. , Triangle Doughnuts , 472 F. Supp. 3d at 129, 135 (listing allegations that plaintiff was prevented from using a bathroom that was consistent with her gender identity as among the allegations that supported her Title VII and ADA hostile work environment claims). In addition to being part of a harassment claim, denial of access to a bathroom consistent with one’s gender identity may be a discriminatory action in its own right and should be evaluated accordingly. See, e.g. , Lusardi , 2015 WL 1607756, at *6-10 (finding that the agency subjected a transgender employee to disparate treatment when it restricted her access to the women’s restroom on account of her gender identity).

44 See Heller v. Columbia Edgewater Country Club , 195 F. Supp. 2d 1212, 1217 (D. Or. 2002) (denying summary judgment to the employer where the alleged harassment included “questions such as, ‘Do you wear the dick in the relationship?’ and, ‘Are you the man?’”).

45 This example is adapted from the facts in Cunningham v. Burlington Coat Factory Warehouse Corp. , No. 1:18-cv-11266, 2024 WL 863236 (D.N.J. Feb. 29, 2024).

Additional cases involving harassment based on gender identity include Copeland , 2024 WL 1316677; Eller v. Prince George’s Cnty. Pub. Sch. , 580 F. Supp. 3d 154 (D. Md. 2022); Grimes v. Cnty. of Cook , 19-cv-6091, 2022 WL 1641887 (N.D. Ill. May 24, 2022); Triangle Doughnuts , 472 F. Supp. 3d 115; Doe v. Arizona , 2019 WL 2929953; and Drew v. U.S. Dep’t of Veterans Affs. , No. CV H-16-3523, 2023 WL 186881 (S.D. Tex. Jan. 12, 2023).

46 29 U.S.C. § 623(a)(1) (“It shall be unlawful for an employer to . . . otherwise discriminate against any individual with respect to . . . [the] terms, conditions, or privileges of employment, because of such individual’s age.”).

47 The ADEA does not apply to discrimination or harassment based on workers being younger than others, such as harassment based on the belief that someone is too young for a certain position, even if the targeted individual is forty or over. See Gen. Dynamics Land Sys., Inc. v. Cline , 540 U.S. 581, 600 (2004) (holding that the ADEA does not prohibit favoring older workers over younger workers, even if the younger workers are within the protected class of individuals forty or older).

48 See, e.g. , Dediol v. Best Chevrolet, Inc. , 655 F.3d 435, 442-43 (5th Cir. 2011) (holding that a fact finder could conclude that the plaintiff, a used car salesperson, was subjected to a hostile work environment based on his age where the plaintiff’s supervisor had made profane, age-based references to the plaintiff up to half a dozen times a day, the supervisor had engaged in physically threatening behavior toward the plaintiff, and the supervisor had “steered” sales away from the plaintiff and toward younger salespersons) .

49 See, e.g. , Davis-Garett v. Urb. Outfitters, Inc. , 921 F.3d 30, 42 (2d Cir. 2019) (the plaintiff adduced sufficient evidence of age-based hostile work environment where, in addition to age-based remarks, “from the start of her employment . . ., [she was] denied the training given to younger sales associates and relegated to work almost exclusively in the fitting room, and later [] assigned the most unpleasant and arduous duties”); Guthrie v. J.C. Penney Co. , 803 F.2d 202, 208 (5th Cir. 1986) (repeated inquiries into the plaintiff’s retirement plans constituted evidence of “intentional harassment” sufficient to support claim of age-based constructive discharge); see also Written Testimony of Patrick Button, Assistant Professor, Department of Economics, Tulane University , EEOC Meeting of June 14, 2017 - The ADEA @ 50 - More Relevant Than Ever, https://www.eeoc.gov/meetings/meeting-june-14-2017-adea-50-more-relevant-ever/button (discussing evidence of age discrimination in hiring).

50 Under Title I of the Americans with Disabilities Act, a disability is “a physical or mental impairment that substantially limits one or more [of an individual’s] major life activities”; a “record of such an impairment”; or “being regarded as having such an impairment,” if the individual establishes that he or she has been subjected to an adverse employment action, such as harassment, because of an actual or perceived physical or mental impairment and that impairment is not both transitory and minor. Id. § 12102(1), (3).

51 42 U.S.C. § 12112(a) (“No covered entity shall discriminate against a qualified individual on the basis of disability in regard to . . . terms, conditions, and privileges of employment.”). Section 501 of the Rehabilitation Act of 1973 prohibits employment discrimination against applicants or employees of the federal government who are individuals with disabilities. 29 U.S.C. § 791. The Rehabilitation Act Amendments of 1992 made clear that the standards applied under Title I of the ADA also apply to Section 501 employment discrimination claims. 29 U.S.C. § 791(g).

52 See, e.g. , Quiles-Quiles v. Henderson , 439 F.3d 1, 4, 7-8 (1st Cir. 2006) (affirming a jury verdict finding that a Postal Service employee was subjected to a hostile work environment based on his mental disability (depression) when supervisors mocked him on a daily basis about his mental impairment and commented to other employees that he was a “great risk” because he was receiving psychiatric treatment); Fox v. Gen. Motors Corp. , 247 F.3d 169, 178-79 (4th Cir. 2001) (upholding a jury finding that the plaintiff, who suffered from chronic back issues, was subjected to a hostile work environment based on disability where two supervisors constantly berated him and other workers with disabilities and encouraged other employees to ostracize workers with disabilities and refuse to give them materials they needed to do their jobs).

53 See, e.g. , Fox v. Costco Wholesale Corp. , 918 F.3d 65, 75-76 (2d Cir. 2019) (concluding that an employee with Tourette’s Syndrome and obsessive compulsive disorder had raised a material issue of fact as to whether he was subjected to ongoing and pervasive discriminatory conduct based on disability when coworkers mocked his verbal and physical tics); Patton v. Jacobs Eng’g Grp., Inc. , 874 F.3d 437, 446 (5th Cir. 2017) (concluding that a reasonable jury could find that the plaintiff was subjected to severe or pervasive disability-based harassment where he had presented evidence that coworkers repeatedly mocked his stutter and his supervisor mocked him in a department-wide meeting); Martsolf v. United Airlines, Inc. , No. 13-1581, 2015 WL 4255636, at *13 (W.D. Pa. July 14, 2015) (rejecting the employer’s motion for summary judgment on the disability-based harassment claim of a plaintiff with a hearing and speech disability where there was evidence that employees screamed at the plaintiff when she could not hear them and mocked the way she spoke); cf. EEOC v. E.I. Du Pont de Nemours & Co. , 480 F.3d 724, 733 (5th Cir. 2007) (affirming jury verdict finding intentional discrimination where, among other things, a supervisor “stated that he no longer wanted to see [the plaintiff’s] ‘cr*ppled crooked self, going down the hall hugging the walls’”).

54 See Patton , 874 F.3d at 446 (concluding that repeated mocking of a stutter “rises above simple teasing and offhand comments” and can support a hostile work environment claim); see also Salas v. N.Y.C. City Dep’t of Investigation , 298 F. Supp. 3d 676, 684-85 (S.D.N.Y. 2018) (concluding that daily mimicking of a stutter by a coworker is “a very specific and self-explanatory form of bullying” that is sufficient to survive a motion to dismiss).

55 See, e.g. , Fox v. Gen. Motors Corp. , 247 F.3d at 174 (upholding a jury verdict on a disability harassment claim based in part on evidence that a supervisor made disparaging comments about employees with disabilities assigned light duty, including calling them “hospital people,” supervising their work more closely, and segregating them from other employees); Pantazes v. Jackson , 366 F. Supp. 2d 57, 71 (D.D.C. 2005) (holding that a jury could find that unreasonably lengthy delays in responding to the plaintiff’s accommodation requests, combined with other harassing acts, were sufficient to establish a hostile work environment).

Harassment based on an individual’s request for, or receipt of, a reasonable accommodation also could violate the ADA’s interference provision, see 42 U.S.C. § 12203(b); 29 C.F.R. § 1630.12(b), and/or the ADA’s retaliation provision, see 42 U.S.C. § 12203(a); EEOC, Enforcement Guidance on Retaliation and Related Issues § II.A.2.e (2016), https://www.eeoc.gov/laws/guidance/enforcement-guidance-retaliation-and-related-issues#e._Example s.

56 42 U.S.C. § 12102(1)(C), (3) (providing that an individual has a disability if the individual is “regarded as having . . . an impairment”; and that an individual meets this requirement if the individual has been “subjected to an action prohibited [under the ADA] because of an actual or perceived physical or mental impairment whether or not the impairment limits or is perceived to limit a major life activity”); 29 C.F.R. § 1630.2(g)(1)(iii) (noting that the ADA’s protections apply where an “individual has been subjected to an action prohibited by the ADA as amended because of an actual or perceived impairment that is not both ‘transitory and minor’”); see, e.g. , Quiles-Quiles , 439 F.3d at 5-8 (concluding with respect to the plaintiff’s disability harassment claim that the evidence supported the jury’s finding that the plaintiff was discriminated against because he was either actually disabled or perceived as such by his employer).

57 42 U.S.C. § 12102(1)(A)-(B) (including within the definition of disability a record of a physical or mental impairment).

58 The ADA expressly prohibits associational discrimination. See 42 U.S.C. § 12112(b)(4) (stating that discrimination against a qualified individual with a disability includes “excluding or otherwise denying equal jobs or benefits to a qualified individual because of the known disability of an individual with whom the qualified individual is known to have a relationship or association”); 29 C.F.R. § 1630.8 (“It is unlawful for a covered entity to exclude or deny equal jobs or benefits to, or otherwise discriminate against , a qualified individual because of the known disability of an individual with whom the qualified individual is known to have a family, business, social or other relationship or association.” (emphasis added)); see, e.g. , Kelleher v. Fred A. Cook, Inc. , 939 F.3d 465, 467-70 (2d Cir. 2019) (ruling that the plaintiff stated a claim of associational discrimination under the ADA where he alleged that he was qualified to perform his job but was discriminated against based on his employer’s perception that he was unavailable or distracted due to his daughter’s medical condition).

Harassment based on association under other EEO statutes also is discussed below at notes 67 -71 and accompanying text.

59 Genetic information is defined to include an “individual’s genetic test,” “genetic tests of family members,” and “the manifestation of a disease or disorder in family members.” 42 U.S.C. § 2000ff(4)(A). The definition of genetic information also includes “any request for, or receipt of, genetic services, or participation in clinical research which includes genetic services, by [an] individual or any family member of such individual.” 42 U.S.C. § 2000ff(4)(B). Genetic information is further defined to include, “with respect to [] an individual or family member of an individual who is a pregnant woman, [the] genetic information of any fetus carried by such pregnant woman,” and “with respect to an individual or family member utilizing an assisted reproductive technology, [the] genetic information of any embryo legally held by the individual or family member.” 42 U.S.C. § 2000ff-8(b).

60 42 U.S.C. § 2000ff-1(a)(1) (“It shall be an unlawful employment practice for an employer to . . . discriminate against any employee with respect to the . . . terms, conditions, or privileges of employment of the employee, because of genetic information with respect to the employee.”).

61 42 U.S.C. § 2000ff(4)(A).

62 Cases alleging harassment under GINA based on the manifestation of a disease or disorder in a family member likely will also be covered by the ADA’s prohibition against associational discrimination. See supra note 58 (discussing associational discrimination under the ADA). For example, if an employee is harassed because the employee’s mother has cancer, then the employee may raise claims under GINA, as well as under the ADA for associational discrimination.

63 E.g. , 42 U.S.C. § 2000e-3(a); see also EEOC, Enforcement Guidance on Retaliation and Related Issues , § II.A (2016), https://www.eeoc.gov/laws/guidance/enforcement-guidance-retaliation-and-related-issues (discussing participation and opposition as protected activity).

64 Burlington N. & Santa Fe Ry. Co. v. White , 548 U.S. 53, 64 (2006); see also Laster v. City of Kalamazoo , 746 F.3d 714, 731 (6th Cir. 2014) (applying the Burlington Northern standard).

65 See, e.g. , Carr v. NYC Transit Auth. , 76 F.4th 172, 181 (2d Cir. 2023) (“[W]hen analyzing a retaliation claim, the sole inquiry regarding the third element of the prima facie case is whether the allegedly retaliatory actions were materially adverse. Even if a plaintiff labels her retaliation claim as a ‘retaliatory hostile work environment’ claim, courts should not consider whether the allegedly retaliatory actions meet the higher ‘severe and [sic] pervasive’ standard. All that is relevant is whether the actions, taken in the aggregate, are materially adverse and would dissuade a reasonable employee from making a complaint of discrimination.”); Chambers v. Dist. of Columbia , 35 F.4th 870, 876 (D.C. Cir. 2022) (en banc) (“[T]here are fundamental differences between the antidiscrimination and the antiretaliation provisions. . . . Unlike the antidiscrimination provision, the antiretaliation provision is not expressly limited to actions affecting the terms, conditions, or privileges of employment.”); Monaghan v. Worldpay US, Inc. , 955 F.3d 855, 862 (11th Cir. 2020) (“[T]he standard applicable to all Title VII retaliation claims is the Burlington Northern ‘well might have dissuaded’ standard.”); Moore v. City of Phila. , 461 F.3d 331, 341-42 (3d Cir. 2006).

66 See, e.g. , Jones v. UPS Ground Freight , 683 F.3d 1283, 1299 (11th Cir. 2012) (“[A] harasser’s use of epithets associated with a different ethnic or racial minority than the plaintiff will not necessarily shield an employer from liability for a hostile work environment.”); EEOC v. WC&M Enters., Inc. , 496 F.3d 393, 401-02 (5th Cir. 2007) (concluding that the EEOC presented sufficient evidence to support its national origin harassment claim where coworkers repeatedly referred to an employee of Indian descent as “Taliban” or “Arab” and stated that “[t]his is America . . . not the Islamic country where you came from,” even though the harassing comments did not accurately describe the employee’s actual country of origin); Goings v. Lopinto , No. 22-2549, 2023 WL 2709826, at *5 (E.D. La. Mar. 30, 2023) (stating that “[d]iscrimination on the basis of sexual orientation, including perceived sexual orientation, is prohibited under Title VII” and denying the employer’s motion to dismiss where the plaintiff alleged he was called slurs and derogatory terms targeting homosexual individuals by his supervisor, who perceived the plaintiff as gay after seeing a photograph of the plaintiff shirtless and wrestling another male coworker); Kallabat v. Mich. Bell Tel. Co. , No. 12-CV-15470, 2015 WL 5358093, at *3-4 (E.D. Mich. June 18, 2015) (denying summary judgment to the employer on the plaintiff’s claim that he was harassed based on the mistaken perception that he was Muslim); Arsham v. Mayor & City Council of Balt. , 85 F. Supp. 3d 841, 844, 849 (D. Md. 2015) (holding that an employee of Persian descent stated a valid claim of national origin discrimination and harassment even though her employer mistakenly believed her to be a member of the Parsee ethnic group, which the plaintiff researched and believed originated in India and was a lower caste). But see, e.g. , Yousif v. Landers McClarty Olathe KS, LLC , No. 12-2788, 2013 WL 5819703, at *3-4 (D. Kan. Oct. 29, 2013) (stating that “perceived” discrimination claims are not cognizable under Title VII); El v. Max Daetwyler Corp. , No. 3:09-CV-415, 2011 WL 1769805, at *5-6 (W.D.N.C. May 9, 2011) (rejecting the proposition that Title VII provides a claim for discrimination based on misperception), aff’d , 451 F. App’x 257 (4th Cir. 2011).

67 See, e.g. , Frith v. Whole Foods Mkt., Inc. , 38 F.4th 263, 272 (1st Cir. 2022) (concluding that claims alleging discrimination based on interracial association “are fundamentally consistent with Bostock v. Clayton County , 590 U.S. 644 (2020)] and Title VII’s plain language prohibiting action ‘because of such individual[ ]’ plaintiff’s race”); Barrett v. Whirlpool Corp. , 556 F.3d 502, 512 (6th Cir. 2009) (observing that “Title VII protects individuals who . . . are ‘victims of discriminatory animus toward [protected] third persons with whom the individuals associate’” and that a complainant may be discriminated against based on his own race because the difference between his race and the race of the individual with whom he associated was the cause of the discrimination (quoting Tetro v. Elliott Popham Pontiac, Oldsmobile, Buick, & GMC Trucks, Inc. , 173 F.3d 988, 994 (6th Cir. 1999))); Holcomb v. Iona Coll. , 521 F.3d 130, 138-39 (2d Cir. 2008) (holding that Title VII prohibits discrimination based on interracial association and observing that multiple other circuits agree); cf. Thompson v. N. Am. Stainless, LP , 562 U.S. 170, 175-78 (2011) (holding that the plaintiff had standing to sue under Title VII where he alleged that his employer terminated him in order to retaliate against his fiancée for a sex discrimination charge she filed against their mutual employer; in authorizing a “person aggrieved” to file a charge or bring a lawsuit, Title VII provides a cause of action to those within the “zone of interests” “arguably [sought] to be protected by the statute”); Kelleher v. Fred A. Cook, Inc. , 939 F.3d 465, 467-70 (2d Cir. 2019) (ruling that the plaintiff had stated a claim of associational discrimination under the ADA where he alleged that he was qualified to perform his job but was discriminated against based on his employer’s perception that he was unavailable or distracted due to his daughter’s medical condition).

68 See, e.g. , Zarda v. Altitude Express, Inc. , 883 F.3d 100, 128 (2d Cir. 2018) (en banc) (“[W]e hold that sexual orientation discrimination, which is based on an employer’s opposition to association between particular sexes and thereby discriminates against an employee based on their own sex, constitutes discrimination ‘because of . . . sex.’”), aff’d on other grounds sub nom. Bostock v. Clayton Cnty ., 590 U.S. 644 (2020).

69 Holcomb , 521 F.3d at 131.

70 Tetro , 173 F.3d at 994 (“A white employee who is discharged because his child is biracial is discriminated against on the basis of his race, even though the root animus for the discrimination is a prejudice against the biracial child.”).

71 See, e.g. , Barrett , 556 F.3d at 513 (concluding that the district court erred in rejecting two White employees’ claim of associational discrimination on the grounds that they failed to show the “requisite degree of association” with Black coworkers and explaining that the degree of association is irrelevant in assessing whether a plaintiff has a valid claim of associational discrimination (citing Drake v. 3M , 134 F.3d 878, 884 (7th Cir. 1998)); cf. Kengerski v. Harper, 6 F.4th 531, 534-35, 539 (3d Cir. 2021) (noting that associational discrimination is not limited to close or substantial relationships and ruling that the complainant could pursue his retaliation claim for making a complaint regarding harassment based on his association with his biracial grand-niece).

72 See, e.g. , Oncale v. Sundowner Offshore Servs., Inc. , 523 U.S. 75, 77-79 (1998) (involving male employees sexually harassing a male coworker); Johnson v. Advocate Health & Hosps. Corp. , 892 F.3d 887, 908 (7th Cir. 2018) (rejecting “entirely” the view that it “strains credulity” that African Americans might be subjected to unlawful race-based harassment where many managers in the same workplace were also African American and explaining that there are many reasons why women and minorities might tolerate discrimination against members of their own class or might participate in the discrimination themselves).

73 See Dediol v. Best Chevrolet, Inc. , 655 F.3d 435, 438 (5th Cir. 2011).

74 This example is adapted from the facts in Kang v. U. Lim Am., Inc. , 296 F.3d 810 (9th Cir. 2002).

75 See, e.g. , Masud v. Rohr-Grove Motors, Inc. , No. 13 C 6419, 2015 WL 5950712, at *3-5 (N.D. Ill. Oct. 13, 2015) (denying summary judgment for the employer on the plaintiff’s harassment claim based on “evidence, viewed in the light most favorable to plaintiff, support[ing] a pervasive pattern of discriminatory harassment based on not one but various protected characteristics all at once”); see also Lam v. Univ. of Haw. , 40 F.3d 1551, 1562 (9th Cir. 1994) (recognizing a claim of intersectional discrimination against an Asian woman, despite favorable consideration of an Asian man and a White woman, noting that “when a plaintiff is claiming race and sex bias, it is necessary to determine whether the employer discriminates on the basis of that combination of factors, not just whether it discriminates against people of the same race or of the same sex” (emphasis in the original)); Jefferies v. Harris Cnty. Cmty. Action Ass’n , 615 F.2d 1025, 1032-34 (5th Cir. 1980) (recognizing that “discrimination against black females can exist even in the absence of discrimination against black men or white women”).

76 See, e.g. , Frappied v. Affinity Gaming Black Hawk, LLC , 966 F.3d 1038, 1048 (10th Cir. 2020) (recognizing Title VII claim alleging discrimination against older women).

77 E.g. , Ahmed v. Astoria Bank , 690 F. App’x 49, 51 (2d Cir. 2017) (holding that a reasonable jury could find that the plaintiff was subjected to unlawful harassment based on race, national origin, and religion, based in part on a senior supervisor’s comments that she should remove her hijab, which he called a “rag,” and his comment on September 11, 2013, that the plaintiff and two other Muslim employees were “suspicious” and that he was thankful he was “in the other side of the building in case you guys do anything”).

78 See, e.g. , Price Waterhouse v. Hopkins , 490 U.S. 228, 250 (1989) (plurality opinion) (“In the specific context of sex stereotyping, an employer who acts on the basis of a belief that a woman cannot be aggressive, or that she must not be, has acted on the basis of gender.”); Tang v. Citizens Bank , 821 F.3d 206 (1st Cir. 2016) (reversing summary judgment for the employer where harassment of an Asian woman included a discussion of the purported obedience of Asian women); EEOC v. Boh Bros. Constr. Co. , 731 F.3d 444, 459 (5th Cir. 2013) (en banc) (upholding a jury verdict on the grounds that a claim that a male employee was harassed because of sex could be established by evidence showing that the male harasser targeted the employee for not conforming to the harasser’s “manly-man” stereotype); Waldo v. Consumers Energy Co. , 726 F.3d 802 (6th Cir. 2013) (harassment of a female employee in a heavily male environment included telling her to “pee like a man” and ridiculing her for carrying a purse); Rosario v. Dep’t of Army , 607 F.3d 241, 244 (1st Cir. 2010) (harassment included a supervisor constantly complaining about the plaintiff’s work attire and bringing coworkers to look at her clothes); Prowel v. Wise Bus. Forms, Inc ., 579 F.3d 285 (3d Cir. 2009) (denying summary judgment for employer where the plaintiff was harassed based on gender stereotypes of how a man should look, speak, and act because the plaintiff had a high voice; walked in a certain manner; did not curse; was very well groomed; crossed his legs; and discussed topics like art, music, and interior design); Kang , 296 F.3d 810 (hostile work environment claim based on supervisor’s stereotypical notions that Korean workers were better than others and that the plaintiff failed to live up to his supervisor’s expectations); Nichols v. Azteca Rest. Enters ., 256 F.3d 864 (9th Cir. 2001) (systemic abuse of a male restaurant employee for failing to conform to male stereotypes); Eller v. Prince George’s Cnty. Pub. Sch. , 580 F. Supp. 3d 154 (D. Md. 2022) (employer’s response to harassment of transgender teacher included trying to hide plaintiff’s gender identity by restricting her clothes, footwear, make-up, and nail polish); Membreno v. Atlanta , 517 F. Supp. 3d 425 (D. Md. 2021) (harassment of transgender worker included questioning how a man could be attracted to her and ridiculing and demeaning her when she used the ladies’ bathroom to the point that she would avoid relieving herself); Doe v. Triangle Doughnuts, LLC , 472 F. Supp. 3d 115, 129 (E.D. Pa. 2020) (harassment of transgender worker included being subjected to a stricter dress code than other female employees); Parker v. Strawser Constr., Inc. , 307 F. Supp. 3d 744 (S.D. Ohio 2018) (denying motion to dismiss transgender woman’s hostile work environment claim, which included allegations that she was told to “just dress like a man,” that she made an “ugly woman,” and that after the worker complained of several years of harassment, she was told to “be like a man” and “act like a man”); Salinas v. Kroger Tex., L.P. , 163 F. Supp. 3d 419 (S.D. Tex. 2016) (harassment of male coworker was based on the harasser’s perception that the plaintiff was effeminate and had “a body like a woman”); Barrett v. Pa. Steel Co. , No. 2:14-CV-01103, 2014 WL 3572888 (E.D. Pa. July 21, 2014) (male plaintiff who worked in “office” portion of facility stated claim of sex harassment where he alleged that he was “made fun of and sexually harassed because he did not participate in cursing or engage in crude banter as did his male co-workers from the ‘shop’ portion of the facility”); Zhao v. State Univ. of New York. , 472 F. Supp. 2d 289, 313 (E.D.N.Y 2007) (denying the employer’s motion for summary judgment where evidence included “facially neutral incidents [that] could be consistent with an employer [] punishing an employee for not achieving a standard of performance that has been improperly inflated due to impermissible ethnic stereotyping” where supervisor allegedly made comments suggesting “Chinese employees should work longer and harder than anyone else”); Rubin v. Kirkland Chrysler-Jeep, Inc. , 98 Fair Empl. Prac. Cas. (BNA) 159, 2006 WL 1009338 (W.D. Wash. Apr. 13, 2006) (harassment included references to stereotypes of Jews as both cheap and unduly interested in money).

79 See Plaetzer v. Borton Auto., Inc. , No. Civ. 02-3089, 2004 WL 2066770, at *6 (D. Minn. Aug. 13, 2004) (concluding that the plaintiff had presented sufficient evidence to send her harassment claim to a jury where she experienced repeated comments and other conduct implying or stating that she was unqualified and could be fired at any time because she was a woman and because she spent too much time caring for her children); see also Chadwick v. Wellpoint , Inc. , 561 F.3d 38, 42, 47-48 (1st Cir. 2009) (holding that a reasonable jury could find that the plaintiff, the mother of an eleven-year-old and six-year-old triplets, was denied a promotion based on the “common stereotype about the job performance of women with children”).

80 See Burns v. Johnson , 829 F.3d 1, 13-14, 17 (1st Cir. 2016) (holding that a reasonable jury could conclude that a male supervisor’s harassment of a female subordinate was based, in part, on the gender stereotype that women do not belong in positions of leadership).

81 See, e.g. , Price Waterhouse , 490 U.S. at 250.

82 Aman v. Cort Furniture Rental Corp. , 85 F.3d 1074, 1082 (3d Cir. 1996) (describing insults directed at Black employees based on negative stereotyping such as “don’t touch anything” and “don’t steal” as “inherently racist”).

83 The causation principles discussed in this enforcement guidance focus on hostile work environment claims. As discussed below in section III.A, however, unlawful harassment can also involve an explicit change to a term, condition, or privilege of employment, such as the denial of a promotion for rejecting sexual advances. For more guidance on how to evaluate an allegation involving an explicit change to employment, refer to EEOC guidance that discusses discriminatory employment decisions. See, e.g. , EEOC, Enforcement Guidance on National Origin Discrimination § III (2016), https://www.eeoc.gov/laws/guidance/eeoc-enforcement-guidance-national-origin-discrimination#_Toc451518806 ; EEOC, Compliance Manual Section 15: Race & Color Discrimination § 15-V.A (2006), https://www.eeoc.gov/laws/guidance/section-15-race-and-color-discrimination#VA .

84 See, e.g. , Tademe v. Saint Cloud State Univ. , 328 F.3d 982, 991 (8th Cir. 2003) (holding that the employer was entitled to summary judgment where evidence showed that harassment was based on inter-departmental politics and personality conflicts).

85 In this example, there was no evidence that the harassment was based on color, national origin, or any another legally protected characteristic. By contrast, harassment based on a legally protected characteristic is covered under EEO law even if it also is based on non-protected reasons.

86 This example is adapted from the facts in Webb v. Merck & Co. , 450 F. Supp. 2d 582 (E.D. Penn. 2006). “A reasonable jury could find that statements such as ‘my animals’ and ‘zookeeper,’ when used in referring solely to African-American employees, ‘send a clear message and carry the distinct tone of racial motivations and implications. They could be seen as conveying the message that members of a particular race are disfavored and that members of that race are, therefore, not full and equal members of the workplace.’” Id. at 597 (quoting Aman v. Cort Furniture Rental Corp. , 85 F.3d 1074, 1083 (3d Cir. 1996)); see also Galdamez v. Potter , 415 F.3d 1015, 1024 n.6 (9th Cir. 2005) (“[T]here are no ‘talismanic expressions’ of racial animus necessary to sustain a harassment claim, and . . . racially charged ‘code words’ may provide evidence of discriminatory intent by ‘sending a clear message and carrying the distinct tone of racial motivations and implications.’” (quoting McGinest v. GTE Serv. Corp. , 360 F.3d 1103, 1117 (9th Cir. 2004))).

For a discussion of how the link between harassment and a protected basis can be established by context, see section II.B.4.

87 See, e.g. , Meritor Sav. Bank, FSB v. Vinson , 477 U.S. 57, 69 (1986) (citing 29 C.F.R. § 1604.11(b) for the proposition that “the trier of fact must determine the existence of sexual harassment in light of ‘the record as a whole’ and ‘the totality of the circumstances’”).

88 In this document, use of the term “discriminatory” to describe conduct means only that the conduct was based on a protected characteristic and does not indicate that conduct necessarily satisfies other legal requirements to establish that the conduct violates federal EEO laws, such as creating a hostile work environment.

89 See, e.g. , Roy v. Correct Care Sols. , LLC , 914 F.3d 52, 63 (1st Cir. 2019) (stating that “the use of sexually degrading, gender-specific epithets, such as . . . ‘b*tch,’ . . . constitute[s] harassment based upon sex” (omissions and second alteration in original) (quoting Forrest v. Brinker Int’l Payroll Co. , 511 F.3d 225, 229 (1st Cir. 2007))); Arrieta-Colon v. Wal-Mart P.R., Inc. , 434 F.3d 75, 80, 89 (1st Cir. 2006) (agreeing with the lower court that there was sufficient evidence to support the jury verdict on the plaintiff’s ADA hostile work environment claim where the plaintiff had a medical condition relating to sexual dysfunction and was subjected to “constant mockery and harassment . . . by fellow coworkers and supervisors alike due to his condition,” including comments about impotence, his “pump,” and his sexual functioning); Spriggs v. Diamond Auto Glass , 242 F.3d 179, 185-86 (4th Cir. 2001) (holding that a workplace where a supervisor constantly referred to African Americans as “monkeys” and “n****rs” was a racially hostile work environment, noting that “the word ‘n****r’ is pure anathema to African-Americans” and that calling someone a “monkey” “goes far beyond the merely unflattering; it is degrading and humiliating in the extreme”).

90 Gallagher v. C.H. Robinson Worldwide, Inc. , 567 F.3d 263, 271 (6th Cir. 2009) (concluding that women were subjected to sex discrimination by conduct that was patently degrading to women, even though members of both sexes were exposed to the conduct, and concluding that such conduct discriminates against women, irrespective of the harasser’s motive); see also Roy , 914 F.3d at 63 (noting that gender-specific epithets can ground a harassment claim “[r]egardless of [the harasser’s] particular and subjective motives”); Winsor v. Hinckley Dodge, Inc. , 79 F.3d 996, 1001 (10th Cir. 1996) (concluding that sex-based epithets discriminated against the plaintiff based on her sex even if they were motivated by gender-neutral reasons); Walker v. Ford Motor Co. , 684 F.2d 1355, 1359 (11th Cir. 1982) (concluding that use of the terms “n****r-rigged” and “black ass” supported a race-based hostile work environment claim even though, the employer asserted, they were not “intended to carry racial overtones”); cf. Int’l Union, United Auto., Aerospace & Agric. Workers of Am. v. Johnson Controls, Inc. , 499 U.S. 187, 199 (1991) (“[T]he absence of a malevolent motive does not convert a facially discriminatory policy into a neutral policy with a discriminatory effect. Whether an employment practice involves disparate treatment through explicit facial discrimination does not depend on why the employer discriminates but rather on the explicit terms of the discrimination.”); Lounds v. Lincare, Inc. , 812 F.3d 1208, 1228-31 (10th Cir. 2015) (concluding that the district court erred in discounting the environmental effect of offensive race-based conduct when the court focused on the “ostensibly benign motivation or intent” of the alleged harassers).

91 Sharp v. S&S Activewear, LLC , 69 F.4th 974, 981 (9th Cir. 2023) (concluding that “sexually graphic, violently misogynistic” music can give rise to a sex-based hostile work environment claim and that even if the music was not directed toward a particular woman, “female employees allegedly experienced the content in a unique and especially offensive way”); Gallagher , 567 F.3d at 271 (concluding that women were subjected to sex discrimination by conduct that was patently degrading to women, even though members of both sexes were exposed to the conduct).

92 This example is adapted from the facts in Mangel v. Graham Packaging Co. , No. 14-CV-0147, 2016 WL 1266257 (W.D. Pa. Apr. 1, 2016).

93 See, e.g. , Price Waterhouse v. Hopkins , 490 U.S. 228, 250 (1989) (plurality opinion) (“In the specific context of sex stereotyping, an employer who acts on the basis of a belief that a woman cannot be aggressive, or that she must not be, has acted on the basis of gender.”); Parker v. Reema Consulting Servs., Inc. , 915 F.3d 297, 303 (4th Cir. 2019) (concluding that the plaintiff’s allegation that male coworkers started a rumor that she had sex with her boss to obtain a promotion invoked the “deeply rooted perception—one that unfortunately still persists—that generally women, not men, use sex to achieve success”); EEOC v. Boh Bros. Constr. Co. , 731 F.3d 444, 459 (5th Cir. 2013) (en banc) (upholding a jury verdict on the grounds that a claim that a male employee was harassed because of sex could be established by evidence showing that the male harasser targeted the employee for not conforming to the harasser’s “manly-man” stereotype).

94 See Plaetzer v. Borton Auto., Inc. , No. Civ. 02-3089, 2004 WL 2066770, at *6 (D. Minn. Aug. 13, 2004) (concluding that the plaintiff had presented sufficient evidence to send her harassment claim to a jury where she experienced repeated comments and other conduct implying or stating that she was unqualified and could be fired at any time because she was a woman and because she spent too much time caring for her children); see also Chadwick v. Wellpoint , Inc. , 561 F.3d 38, 42, 47-48 (1st Cir. 2009) (holding that a reasonable jury could find that the plaintiff, the mother of an eleven-year-old and six-year-old triplets, was denied a promotion based on the “common stereotype about the job performance of women with children”).

95 See Burns v. Johnson , 829 F.3d 1, 13-14, 17 (1st Cir. 2016) (holding that a reasonable jury could conclude that a male supervisor’s harassment of a female subordinate was based, in part, on the gender stereotype that women do not belong in positions of leadership).

96 See, e.g. , Price Waterhouse , 490 U.S. at 250.

97 See King v. Aramark Servs., Inc. , 96 F.4th 546, 564 (2d Cir. 2024) (“[A] reasonable jury could conclude that Thomas’s singling out of King for weight-related remarks and conduct—remarks and conduct that he did not direct toward her male peers—reflected not only a bias against individuals with certain body types, but also a gender-based bias.”).

98 See, e.g. , Glenn v. Brumby , 663 F.3d 1312, 1316 (11th Cir. 2011) (observing that a person is considered transgender “precisely because of the perception that his or her behavior transgresses gender stereotypes” (citing Price Waterhouse , 490 U.S. at 251)); Smith v. City of Salem , 378 F.3d 566, 575 (6th Cir. 2004) (stating that “discrimination against a plaintiff who is trans[gender]—and therefore fails to act and/or identify with his or her gender—is no different from the discrimination directed against Ann Hopkins in Price Waterhouse who, in sex-stereotypical terms, did not act like a woman”); see also supra note 78.

99 See McGinest v. GTE Serv. Corp. , 360 F.3d 1103, 1117 (9th Cir. 2004) (referring to a Black employee as a “drug dealer” “might certainly be deemed to be a [racial] code word or phrase” (citing Daniels v. Essex Grp., Inc. , 937 F.2d 1264, 1273 (7th Cir. 1991))).

100 See Aman v. Cort Furniture Rental Corp. , 85 F.3d 1074, 1082 (3d Cir. 1996) (describing insults directed at Black employees based on negative stereotyping such as “don’t touch anything” and “don’t steal” as “inherently racist”).

101 See, e.g. , Kang v. U. Lim Am., Inc. , 296 F.3d 810, 817 (9th Cir. 2002) (concluding that the plaintiff could establish that he was harassed based on his national origin, Korean, where his supervisor allegedly subjected Korean workers to abuse based, in part, on their failure to “live up” to the stereotype that Korean workers are “better than the rest”).

102 See, e.g. , Tomassi v. Insignia Fin. Grp., Inc. , 478 F.3d 111, 116 (2d Cir. 2007) (holding that “the relevance of discrimination-related remarks does not depend on their offensiveness, but rather on their tendency to show that the decision-maker was motivated by assumptions or attitudes relating to the protected class,” and observing that a supervisor’s assertion that an employee, who was in her sixties, was well suited to work with seniors was not offensive but nevertheless had a strong tendency in the circumstances to show that the supervisor believed the employee, because of her age, was not well-suited to deal with younger clientele), abrogated on other grounds by Gross v. FBL Fin. Servs., Inc. , 557 U.S. 167 (2009).

103 See, e.g. , Sheehan v. Donlen Corp. , 173 F.3d 1039, 1044-45 (7th Cir. 1999) (upholding a jury verdict where a reasonable jury could conclude that “a supervisor’s statement to a woman known to be pregnant that she was being fired so that she could ‘spend more time at home with her children’ reflected unlawful motivations because it invoked widely understood stereotypes the meaning of which is hard to mistake”).

104 This example is adapted from the facts in EEOC v. Boh Bros. Construction Co. , 731 F.3d 444, 449-50, 457-60 (5th Cir. 2013) (en banc) (applying Oncale v. Sundowner Offshore Services,, Inc. , 523 U.S. 75 (1998), which recognized that same-sex sexual harassment can violate Title VII).

105 See, e.g. , Roy v. Correct Care Sols., LLC , 914 F.3d 52, 63 (1st Cir. 2019) (noting that “a reasonable jury could infer that” a comment about the plaintiff’s body “was made in part because of her sex, given the context” that included evidence that her coworkers regularly “sexualiz[ed]” her and “emphasiz[ed] aspects of her appearance, such as her blonde hair”); Tang v. Citizens Bank, N.A. , 821 F.3d 206, 216-17 (1st Cir. 2016) (considering the context, use of the word “ass” was based on sex); McGullam v. Cedar Graphics, Inc. , 609 F.3d 70, 85 (2d Cir. 2010) (Calabresi, J., concurring) (viewing comment by male coworker about the plaintiff’s “big fat ass” to be based on sex).

106 Ash v. Tyson Foods, Inc. , 546 U.S. 454, 456 (2006) (per curiam); see also Paasewe v. Action Grp., Inc. , 530 F. App’x 412, 416 (6th Cir. 2013) (per curiam) (holding that a reasonable jury could find that the plaintiff was subjected to race-based harassment where the plaintiff’s coworker called him “boy” and threatened his life).

107 See Aman v. Cort Furniture Rental Corp. , 85 F.3d 1074, 1082-83 (3d Cir. 1996) (stating that racial harassment could be based on “code words,” which referred to Black employees as “another one,” “one of them,” “that one in there,” and “all of you”); cf. Martin v. Brondum , 535 F. App’x 242, 244 (4th Cir. 2013) (explaining in a case involving an alleged violation of the Fair Housing Act that “[r]acially charged code words may provide evidence of discriminatory intent by sending a clear message and carrying the distinct tone of racial motivations and implications” (alteration in original) (quoting Guimaraes v. SuperValu, Inc. , 674 F.3d 962, 974 (8th Cir. 2012))); Gipson v. KAS Snacktime Co. , 171 F.3d 574, 579 (8th Cir. 1999) (characterizing a supervisor’s use of the phrase, “your kind” as “offensive and racially tinged”).

108 This example is adapted from the facts in Jones v. UPS Ground Freight , 683 F.3d 1283 (11th Cir. 2012).

109 See, e.g. , Rasmy v. Marriott Int’l, Inc. , 952 F.3d 379, 388 (2d Cir. 2020) (“Our case law is clear that when the same individuals engage in some harassment that is explicitly discriminatory and some that is not, the entire course of conduct is relevant to a hostile work environment claim.”); Kaytor v. Elec. Boat Corp. , 609 F.3d 537, 547-48 (2d Cir. 2010) (stating that circumstantial evidence that facially sex-neutral acts were part of a pattern of sex discrimination may include evidence that the same individual engaged in multiple acts of harassment, some facially sex-based and some not); Chavez v. New Mexico , 397 F.3d 826, 833 (10th Cir. 2005) (stating that conduct that appears sex-neutral in isolation may appear sex-based when viewed in the context of the broader work environment); Shanoff v. Ill. Dep’t of Hum. Servs. , 258 F.3d 696, 705 (7th Cir. 2001) (stating that a reasonable person could conclude that comments that were not facially discriminatory were “sufficiently intertwined” with facially discriminatory remarks to establish that the former were motivated by hostility to the plaintiff’s race and religion); O’Rourke v. City of Providence , 235 F.3d 713, 730 (1st Cir. 2001) (stating that “[c]ourts should avoid disaggregating a hostile work environment claim, dividing conduct into instances of sexually oriented conduct and instances of unequal treatment, then discounting the latter category”).

110 See, e.g. , Smith v. Fairview Ridges Hosp. , 625 F.3d 1076, 1085 (8th Cir. 2010) (concluding that instances of facially neutral harassment were not connected to overtly racial conduct as they “lack[ed] any congruency of person or incident”), abrogated on other grounds by Torgerson v. City of Rochester , 643 F.3d 1031, 1043 (8th Cir. 2011) (en banc).

111 This example is adapted from the facts in EEOC v. T-N-T Carports, Inc. , No. 1:09-CV-27, 2011 WL 1769352 (M.D.N.C. May 9, 2011).

112 See, e.g. , Flowers v. S. Reg’l Physician Servs., Inc. , 247 F.3d 229, 236-37 (5th Cir. 2001) (upholding a jury verdict and concluding that the jury could have found that harassment, which began “almost immediately” after a supervisor learned that the plaintiff was HIV-positive, was based on disability).

113 See EEOC v. Nat’l Educ. Ass’n, Alaska , 422 F.3d 840, 842 (9th Cir. 2005) (holding that “offensive conduct that is not facially sex-specific nonetheless may violate Title VII if there is sufficient circumstantial evidence of qualitative and quantitative differences in the harassment suffered by female and male employees”).

114 This example is adapted from the facts in National Education Ass’n, Alaska , 422 F.3d at 842-44.

115 Oncale v. Sundowner Offshore Servs., Inc. , 523 U.S. 75, 80-81 (1998).

116 See EEOC v. Boh Bros. Constr. Co. , 731 F.3d 444, 455-56 (5th Cir. 2013) (en banc) (agreeing with sister circuits that the three evidentiary paths in Oncale are not exclusive); see also, e.g. , Medina v. Income Support Div. , 413 F.3d 1131, 1135 (10th Cir. 2005) (“These routes, however, are not exhaustive.”); Pedroza v. Cintas Corp. No. 2 , 397 F.3d 1063, 1068 (8th Cir. 2005) (describing Oncale ’s list as “non-exhaustive”).

117 Boh Bros. , 731 F.3d at 456.

118 See, e.g. , 42 U.S.C. 2000e-2(a)(1) (“It shall be an unlawful employment practice for an employer . . . to discriminate against any individual with respect to his . . . terms, conditions, or privileges of employment, because of such individual’s race, color, religion, sex, or national origin.”).

119 With respect to harassment claims, the Supreme Court has referred to two types of changes to the terms, conditions, or privileges of employment as “explicit” and “constructive” changes. See Burlington Indus., Inc. v. Ellerth , 524 U.S. 742, 752 (1998). The terms are used in this document to facilitate discussion of the standards attached to each type of change to the terms or conditions of employment.

120 See Meritor Sav. Bank, FSB v. Vinson , 477 U.S. 57, 65 (1986); see also Ellerth , 524 U.S. at 752 (stating that “Title VII is violated by either explicit or constructive alterations in the terms or conditions of employment”).

121 Quid pro quo harassment also has arisen in the context of religious harassment where a supervisor denies a job benefit to an employee who refuses to adhere to the supervisor’s religious principles. See Venters v. City of Delphi, 123 F.3d 956, 976-77 (7th Cir. 1997) (concluding that a jury could find that a radio dispatcher was subjected to quid pro quo religious harassment when she was discharged by the police chief for not adhering to his religious beliefs).

122 See, e.g. , Barnes v. Costle , 561 F.2d 983, 989-90 (D.C. Cir. 1977) (holding that the plaintiff had alleged discrimination based on her sex when she rejected her supervisor’s advances and her position was abolished; the plaintiff alleged that, as a woman, she had been the target of her supervisor’s sexual desires and no male had been subjected to similar conduct); cf. Meritor Sav. Bank, FSB , 477 U.S. at 65 (distinguishing between a sexual harassment claim linked to the “grant or denial of an economic quid pro quo ” and a hostile work environment claim).

123 Gregory v. Daly , 243 F.3d 687, 698 (2d Cir. 2001).

124 Brief for the United States and the Equal Employment Opportunity Commission as Amici Curiae Supporting Respondent at 16, Burlington Indus., Inc. v. Ellerth , 524 U.S. 742 (1998) (No.97-569), 1998 WL 151472, at *16 (alterations in original) (quoting 42U.S.C. §2000e-2(a)(1)); see also Ellerth , 524 U.S. at 752 (noting that the terms “quid pro quo” and “hostile work environment” do not appear in the text of Title VII).

125 Ellerth , 524 U.S. at 753-54; see also Chambers v. District of Columbia , 35 F.4th 870, 874-75 (D.C. Cir. 2022) (en banc) (“Once it has been established that an employer has discriminated against an employee with respect to that employee’s ‘terms, conditions, or privileges of employment’ because of a protected characteristic, the analysis is complete.”).

126 Harris v. Forklift Sys., Inc. , 510 U.S. 17, 21-22 (1993).

128 Id. at 21 (quoting Meritor Sav. Bank , FSB , v. Vinson , 477 U.S. 57, 64 (1986).

129 Morris v. City of Colo. Springs , 666 F.3d 654, 664 (10th Cir. 2012) (citing, e.g., Faragher v. City of Boca Raton , 524 U.S. 775, 788 (1998)); see also Oncale v. Sundowner Offshore Servs., Inc. , 523 U.S. 75, 81 (1998) (stating that the requirement of severity or pervasiveness “prevents Title VII from expanding into a general civility code”); Ziskie v. Mineta , 547 F.3d 220, 228 (4th Cir. 2008) (stating that an employee must “accommodate the normal run of aggravations that are part of holding a job”).

130 Harris , 510 U.S . at 21.

131 Section III.C.1, below, discusses how to determine whether conduct is sufficiently related to be part of the same hostile work environment claim.

132 See infra notes 200-204 and accompanying text.

133 Meritor Savings Bank, FSB , 477 U.S. at 68 (citation omitted).

134 29 C.F.R. § 1604.11(a) (defining sexual harassment as including “[u]nwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature”).

135 Meritor Sav. Bank, FSB , 477 U.S. at 68.

136 Harris , 510 U.S. at 21-22.

137 See, e.g ., Johnson v. Advocate Health & Hosps. Corp. , 892 F.3d 887, 904 (7th Cir. 2018) (holding that, because a reasonable jury could find that the conduct was unwelcome, there was an issue of material fact regarding subjective hostility); Kokinchak v. Postmaster Gen. of the U.S , 677 F. App’x 764, 767 (3d Cir. 2017) (treating unwelcomeness and subjective hostility as the same issue); Horney v. Westfield Gage Co. , Inc. , 77 F. App’x 24, 29 (1st Cir. 2003) (treating unwelcomeness and subjective hostility as the same issue); Nichols v. Azteca Rest. Enters., Inc. , 256 F.3d 864, 873 (9th Cir. 2001) (explaining that the issue of subjective hostility turns on whether conduct was unwelcome to the plaintiff).

138 See, e.g. , Blomker v. Jewell , 831 F.3d 1051, 1056 (8th Cir. 2016) (stating that unwelcomeness is one of the requirements in establishing a hostile work environment based on sex); Smith v. Rock-Tenn Servs., Inc. , 813 F.3d 298, 307 (6th Cir. 2016) (same); Boyer-Liberto v. Fontainebleau Corp. , 786 F.3d 264, 277 (4th Cir. 2015) (en banc) (stating that unwelcomeness is one of the requirements in establishing a hostile work environment based on race); Adams v. Austal, U.S.A., LLC , 754 F.3d 1240, 1248 (11th Cir. 2014) (same).

139 See, e.g. , Smelter v. S. Home Care Servs. Inc. , 904 F.3d 1276, 1285 (11th Cir. 2018) (concluding that the plaintiff’s testimony about the impact that the alleged racial harassment had on her was sufficient for a jury to find that the plaintiff subjectively perceived the conduct as hostile, notwithstanding her failure to report the conduct to supervisors); McGinest v. GTE Serv. Corp. , 360 F.3d 1103, 1113 (9th Cir. 2004) (concluding that subjective hostility was established through the plaintiff’s unrebutted testimony and his complaints to supervisors and the EEOC); Horney , 77 F. App’x at 29 (concluding that subjective hostility/unwelcomeness was established by the plaintiff’s testimony that the conduct she complained about made her feel offended and humiliated); Nichols , 256 F.3d at 873 (concluding that subjective hostility/unwelcomeness was established by the plaintiff’s complaints and his unrebutted testimony that conduct was unwelcome); Davis v. U.S. Postal Serv. , 142 F.3d 1334, 1341-42 (10th Cir. 1998) (concluding that evidence established a jury issue as to subjective hostility where the plaintiff testified that harassment made her “more and more stressed out and pretty cracked,” that she “hated” the conduct, that she was “pretty shocked,” and that she “just wanted to avoid the whole situation”).

140 See, e.g. , Wallace v. Performance Contractors, Inc. , 57 F.4th 209, 223 (5th Cir. 2023) (concluding that the plaintiff presented sufficient evidence that she subjectively viewed the alleged harassment as hostile where she “complained about the harassment, reported it to her supervisors, and suffered psychological harm”); EEOC v. Mgmt. Hosp. of Racine, Inc. , 666 F.3d 422, 433 (7th Cir. 2012) (concluding that there was sufficient evidence in the record showing that a teenage server at a restaurant found her supervisor’s comments and conduct subjectively offensive because she repeatedly informed him that his conduct was unwelcome and complained to two other restaurant managers about the conduct).

141 See Dey v. Colt Constr. & Dev. Co. , 28 F.3d 1446, 1454 (7th Cir. 1994) (concluding that the plaintiff established harassment was subjectively hostile where, among other things, she told a friend about the conduct and then complained to her supervisor after learning from the friend that she had some legal recourse).

142 See EEOC v. Prospect Airport Servs. , 621 F.3d 991, 997-98 (9th Cir. 2011) (explaining that whether the male complainant welcomed his female coworker’s sexual propositions depended on his “individual circumstances and feelings” and that it did not matter whether other men would have welcomed the propositions).

143 See Meritor Sav. Bank, FSB v. Vinson , 477 U.S. 57, 68 (1986) (explaining that the correct inquiry is whether the complainant experienced the conduct as unwelcome, not whether she voluntarily participated in it); Kramer v. Wasatch Cnty. Sheriff’s Off. , 743 F.3d 726, 754-55 (10th Cir. 2014) (concluding that the issue of whether sexual conduct was unwelcome was a matter for the jury to decide, regardless of whether the plaintiff’s participation in it was voluntary).

144 See, e.g. , Kratzer v. Rockwell Collins, Inc., 398 F.3d 1040, 1047-48 (8th Cir. 2005) (concluding that the complainant failed to establish a prima facie case of sexual harassment where she stated that she did not feel harassed by the conduct); Newman v. Fed. Express Corp. , 266 F.3d 401, 405-06 (6th Cir. 2001) (concluding that the plaintiff did not subjectively perceive conduct as hostile where he testified during a deposition that he did not consider a racially charged hate letter a “big deal,” that he was not surprised, shocked, or disturbed by it, and that he would lose no sleep over it).

145 See, e.g. , Williams v. Herron , 687 F.3d 971, 975 (8th Cir. 2012) (concluding that the complainant adequately communicated to the harasser, with whom she had been having a sexual relationship, that his conduct was no longer welcome).

146 Cf. Kramer , 743 F.3d at 749 n.16 (stating that the complainant’s private consensual sexual relationship with another county employee was unrelated to her claim of sexual harassment by the sergeant).

147 See Gerald v. Univ. of P.R. , 707 F.3d 7, 17 (1st Cir. 2013) (stating that telling risqué jokes did not signal that the plaintiff was amenable to being groped at work); Pérez-Cordero v. Wal-Mart P.R., Inc. , 656 F.3d 19, 28 (1st Cir. 2011) (stating that acquiescence to a customary greeting among employees—a kiss on the cheek—was not probative of the complainant’s receptiveness to his supervisor’s sucking on his neck).

148 Harris v. Forklift Sys., Inc. , 510 U.S. 17, 21 (1993); Hall v. City of Chi. , 713 F.3d 325, 330 (7th Cir. 2013) (stating that harassment is actionable if it is severe or pervasive and that, thus, “one extremely serious act of harassment could rise to an actionable level as could a series of less severe acts” (quoting Haugerud v. Amery Sch. Dist. , 259 F.3d 678, 693 (7th Cir. 2001))).

149 See, e.g. , Alamo v. Bliss , 864 F.3d 541, 550 (7th Cir. 2017) (explaining that in determining whether offensive language created a hostile work environment, the court “look[s] to the ‘pervasiveness and severity’ of language used, which [the court has] described as being ‘inversely related’” (quoting Cerros v. Steel Techs., Inc. , 398 F.3d 944, 951 (7th Cir. 2005))); Flood v. Bank of Am. Corp ., 780 F.3d 1, 11-12 (1st Cir. 2015) (explaining that harassment may be actionable without being both severe and pervasive and that the “severity . . . may vary inversely with its pervasiveness” (quoting Nadeau v. Rainbow Rugs, Inc. , 675 A.2d 973, 976 (Me. 1996))); EEOC v. Prospect Airport Servs., Inc. , 621 F.3d 991, 1000 (9th Cir. 2010) (stating that the “required level of severity or seriousness varies inversely with the pervasiveness or frequency of the conduct” (quoting Nichols v. Azteca Rest. Enters., Inc. , 256 F.3d 864, 872 (9th Cir. 2001))).

150 Rodgers v. W.-S. Life Ins. Co. , 12 F.3d 668, 674 (7th Cir. 1993) (“Within the totality of circumstances, there is neither a threshold ‘magic number’ of harassing incidents that gives rise, without more, to liability as a matter of law nor a number of incidents below which a plaintiff fails as a matter of law to state a claim.”); see also Harris , 510 U.S. at 22 (explaining that the determination of whether harassment creates a hostile work environment “is not, and by its very nature cannot be, a mathematically precise test”).

151 A hostile work environment may be so intolerable that an employee is compelled to resign employment. Under these circumstances, the employee is said to have been subjected to a constructive discharge. Pa. State Police v. Suders , 542 U.S. 129, 134 (2004). To establish a constructive discharge claim under such circumstances, the employee must both establish a hostile work environment and show that “working conditions [became] so intolerable that a reasonable person in the employee’s position would have felt compelled to resign.” Id. at 141; see also id. at 149 (“Creation of a hostile work environment is a necessary predicate to a hostile-environment constructive discharge case.”); Green v. Brennan , 578 U.S. 547, 559 (2016) (observing that Suders ’s holding that a hostile work environment claim is a “lesser included component” of the “graver claim” of constructive discharge was “no mere dictum” (emphasis omitted)). “[H]arassment so intolerable as to cause a resignation may be effected through co-worker conduct, unofficial supervisory conduct, or official company acts.” Suders , 542 U.S. at 148.

152 See, e.g. , Harris , 510 U.S. at 23 (“[W]hether an environment is ‘hostile’ or ‘abusive’ can be determined only by looking at all the circumstances.”).

154 See Chai R. Feldblum & Victoria A. Lipnic, EEOC, Select Task Force on the Study of Harassment in the Workplace, Report of Co-Chairs Chai R. Feldblum & Victoria A. Lipnic 28 (2016), https://www.eeoc.gov/sites/default/files/migrated_files/eeoc/task_force/harassment/report.pdf .

155 Harris , 510 U.S. at 23.

156 EEOC v. WC&M Enters., Inc. , 496 F.3d 393, 400-01 (5th Cir. 2007) (concluding that the evidence was sufficient to show that harassment based on an employee’s Muslim faith and national origin (Indian) resulted in a hostile work environment); see also Mosby-Grant v. City of Hagerstown , 630 F.3d 326, 335-36 (4th Cir. 2010) (concluding that race-based conduct could be considered cumulatively with sex-based conduct, which would allow a reasonable jury to find that the plaintiff was subjected to a hostile work environment); Hafford v. Seidner , 183 F.3d 506, 515-16 (6th Cir. 1999) (“It would not be right to require a judgment against Hafford if the sum of all of the harassment he experienced was abusive, but the incidents could be separated into several categories, with no one category containing enough incidents to amount to ‘pervasive’ harassment.”).

Refer to section III.C.1 for a discussion of how to determine whether conduct is sufficiently related to be considered part of the same hostile work environment claim.

157 See Hicks v. Gates Rubber Co. , 833 F.2d 1406, 1416-17 (10th Cir. 1987) (determining that although the plaintiff’s evidence of a race-based hostile work environment was insufficient to establish a hostile work environment, this evidence should be considered with the plaintiff’s evidence of sexual harassment “to determine whether there was a pervasive discriminatory atmosphere . . . so that a hostile work environment harassment claim may have been established”); cf. Cruz v. Coach Stores, Inc. , 202 F.3d 560, 572 (2d Cir. 2000) (stating that the “interplay between the two forms of harassment” alleged by the plaintiff could lead a jury to conclude that the “racial harassment exacerbated the effect of [the] sexually threatening behavior and vice versa”).

158 See, e.g. , Petrosino v. Bell Atl. , 385 F.3d 210, 215 (2d Cir. 2004) (reversing summary judgment for the employer where the hostile work environment included disparaging remarks about the plaintiff’s menstrual cycle, including “dismissing her job concerns as attributable to her menstrual cycle (‘He accused me several times of being ‘on the rag’ . . . whenever I had a dispute with him . . . .”) (internal citation omitted)).

159 This example is adapted from the facts in Preuss v. Kolmar Labs., Inc. , 970 F. Supp. 2d 171 (S.D.N.Y. 2013).

160 Burlington Indus., Inc. v. Ellerth, 524 U.S. 742, 752 (1998) (reiterating that that an employer’s sexually demeaning behavior alters the terms or conditions of employment in violation of Title VII if it is severe or pervasive); see also Ford v. Jackson Nat’l Life Ins. Co., 45 F.4th 1202, 1231 (10th Cir. 2022) (stating that if “the condition of Ford’s employment was altered for the worse” because of the alleged sexual harassment, then the fact that she “continued to proceed through the ranks” provided “no reason” for the court to dismiss her hostile work environment claim); EEOC v. Fairbrook Med. Clinic, P.A. , 609 F.3d 320, 330 (4th Cir. 2010) (stating that the issue is not whether work has been impaired but whether the work environment has been discriminatorily altered and that the “fact that a plaintiff continued to work under difficult conditions is to her credit, not the harasser’s”); Gallagher v. C.H. Robinson Worldwide, Inc. , 567 F.3d 263, 274 (6th Cir. 2009) (concluding that the district court erred in requiring evidence that the complainant’s work performance suffered measurably as a result of harassment rather than merely evidence that harassment made it more difficult to do the job); Dawson v. Cnty. of Westchester, 373 F.3d 265, 274 (2d Cir. 2004) (stating that the crucial question is “whether the workplace atmosphere, considered as a whole, undermined plaintiffs’ ability to perform their jobs, compromising their status as equals to men in the workplace”).

161 Harris, 510 U.S. at 22-23 (explaining that “Title VII comes into play before the harassing conduct leads to a nervous breakdown” as “[a] discriminatorily abusive work environment, even one that does not seriously affect employees’ psychological well-being, can and often will detract from employees’ job performance”) .

162 This example is adapted from the facts in Gallagher , 567 F.3d at 266-69.

163 Ellerth, 524 U.S. at 763; Boyer-Liberto v. Fountainebleau Corp., 786 F.3d 264, 278 (4th Cir. 2015) (en banc) (quoting Ellerth, 524 U.S. at 763); see also Copeland v. Ga. Dep’t of Corr ., ___ F.4th ___, No. 22-13073, 2024 WL 1316677, at *7 (11th Cir. Mar. 28, 2024) (noting that harassment is “more severe when it involves participation of supervisors rather than solely peers or subordinates”).

164 See Gates v. Bd. of Educ., 916 F.3d 631, 638 (7th Cir. 2019) (stating that the circuit has “repeatedly treated a supervisor’s use of racially toxic language in the workplace as much more serious than a coworker’s”); Zetwick v. Cnty. of Yolo, 850 F.3d 436, 445 (9th Cir. 2017) (concluding that a reasonable jury could find that the alleged sexual harassment was actionable, in part, because of the harasser’s status as a supervisor); Steck v. Francis, 365 F. Supp. 2d 951, 971-72 (N.D. Iowa 2005) (stating that a supervisor’s agency relation increases the impact of harassment by the supervisor); see also Fairbrook Med. Clinic, P.A., 609 F.3d at 329 (stating that the severity of the harasser’s conduct was exacerbated by his significant authority over the complainant); Rodgers v. W.-S. Life Ins. Co. , 12 F.3d 668, 675 (7th Cir. 1993) (stating that a supervisor’s use of the word “n****r” has a more severe impact on the work environment than its use by coworkers); cf. Chapman v. Oakland Living Ctr., Inc., 48 F.4th 222, 231 (4th Cir. 2022) (stating that although the repeated use of the n-word was by a six-year-old, “ the boy who uttered the slurs was not just any ‘young child,’ but the grandson of OLC’s owners and the son of a supervisor being groomed to take over the family business . . . and [t]hus, a reasonable person in Chapman’s position could ‘fear that the child had his relative’s ear and could make life difficult for her’” (citation omitted)).

165 See Boyer-Liberto, 786 F.3d at 279-80 (explaining that, regardless of whether the harasser was the complainant’s supervisor for purposes of employer vicarious liability, the determination of objective severity required the court to consider how the harasser portrayed the harasser’s authority and what the complainant reasonably believed the harasser’s actual power to be).

166 See, e.g. , Warf v. U.S. Dep’t of Veterans Affs. , 713 F.3d 874, 878 (6th Cir. 2013) (“Evidence of other sexual harassment claims may help support a hostile work environment claim, but evidence of harassment to others does not weigh as heavily as evidence directed against the plaintiff.”); Ziskie v. Mineta , 547 F.3d 220, 224-25 (4th Cir. 2008) (stating that conduct personally experienced by the plaintiff may be more probative of a hostile work environment than conduct she did not witness, but all the evidence should be considered: “[h]ostile conduct directed toward a plaintiff that might of itself be interpreted as isolated or unrelated to gender might look different in light of evidence that a number of women experienced similar treatment”); see also infra notes 212-216 and accompanying text.

167 See, e.g. , Copeland , 2024 WL 1316677, at *8 (stating that the intentional misgendering and other harassment that a male transgender correctional officer experienced was humiliating where it occurred over the prison radio system, which allowed the whole institution to hear); Howley v. Town of Stratford , 217 F.3d 141, 154 (2d Cir. 2000) (concluding that a fire lieutenant could establish a hostile work environment based on a single incident in which a coworker loudly made obscene and sexist comments at a meeting where the lieutenant was the only woman and many of the men were her subordinates); Delozier v. Bradley Cnty. Bd. of Educ. , 44 F. Supp. 3d 748, 759 (E.D. Tenn. 2014) (concluding that a male band leader’s sexual comments about a female assistant band leader were sufficient to create a hostile work environment where they were made in front of the assistant band leader’s students, thereby undermining her authority and stature in her students’ eyes); Hanna v. Boys & Girls Home & Fam. Servs., Inc. , 212 F. Supp. 2d 1049, 1061 (N.D. Iowa 2002) (noting the significance of the fact that sexually harassing conduct was directed at the female complainant in the presence of male clients).

168 See, e.g. , Jenkins v. Univ. of Minn. , 838 F.3d 938, 945-46 (8th Cir. 2016) (“Actions that might not rise to the level of severe or pervasive in an office setting take on a different character when the two people involved are stuck together for twenty-four hours a day with no other people—or means of escape—for miles around.”).

169 See Chai R. Feldblum & Victoria A. Lipnic, EEOC, Select Task Force on the Study of Harassment in the Workplace, Report of Co-Chairs Chai R. Feldblum & Victoria A. Lipnic 24-25 (2016), https://www.eeoc.gov/sites/default/files/migrated_files/eeoc/task_force/harassment/report.pdf (discussing “superstar” harassers).

170 See, e.g. , Lapka v. Chertoff , 517 F.3d 974, 982-84 (7th Cir. 2008) (concluding that, in the case of a complainant who alleged that her coworker raped her, the severity of the sexual assault alleged would be sufficient to establish an objectively hostile work environment).

171 See, e.g., Turner v. Saloon, Ltd., 595 F.3d 679, 686 (7th Cir. 2010) (concluding that the plaintiff’s claim that his female supervisor grabbed his penis through his pockets was probably severe enough on its own to create a genuine issue of material fact as to the plaintiff’s sexual harassment claim).

172 See, e.g. , Banks v. Gen. Motors, LLC , 81 F.4th 242, 263-64 (2d Cir. 2023) (concluding that a reasonable jury could find that the plaintiff was subjected to unlawful harassment based on race and sex when a colleague “shook a rolled-up document in her face and started yelling at her in a loud and aggressive manner,” alarming other employees, and leading her to take disability leave); Patterson v. Cnty. of Oneida , 375 F.3d 206, 230 (2d Cir. 2004) (concluding that a hostile work environment based on race could be established by a single incident in which the plaintiff was allegedly punched in the ribs and temporarily blinded by having mace sprayed in his eyes because of his race); Smith v. Sheahan , 189 F.3d 529, 534 (7th Cir. 1999) (concluding that harassing a female employee based on her sex by damaging her wrist to the point that surgery was required “easily qualifies as a severe enough isolated occurrence to alter the conditions of her employment”); cf. Pryor v. United Air Lines, Inc. , 791 F.3d 488, 496-97 (4th Cir. 2015) (concluding that a reasonable jury could find that two anonymous notes placed in the plaintiff’s mailbox, although not pervasive, were sufficiently severe to create hostile work environment where the notes referred to lynching and were in the form of a mock hunting license for African Americans).

173 E.g. , Tademy v. Union Pac. Corp. , 614 F.3d 1132, 1145 (10th Cir. 2008) (concluding that a “jury could easily find that the noose was an egregious act of discrimination calculated to intimidate African-Americans”); Rosemond v. Stop & Shop Supermarket Co. , 456 F. Supp. 2d 204, 213 (D. Mass. 2006) (holding that a reasonable jury could conclude that display of a noose in an African American employee’s work area was sufficient to create a hostile work environment); Williams v. N.Y.C. Hous. Auth. , 154 F. Supp. 2d 820, 824 (S.D.N.Y. 2001) (stating that a “noose is among the most repugnant of all racist symbols, because it is itself an instrument of violence” and that the “effect of such violence on the psyche of African-Americans cannot be exaggerated”); Yudovich v. Stone , 839 F. Supp. 382, 391 (E.D. Va. 1993) (finding that one of the plaintiffs’ supervisors expressed hostility toward the plaintiffs’ religion by, among other things, keeping a coffee mug displaying a swastika on his desk).

174 See, e.g. , Boyer-Liberto v. Fountainebleau Corp., 786 F.3d 264, 280 (4th Cir. 2015) (en banc) (stating that calling an African American employee “porch monkey” was “about as odious as the use of the word ‘n****r’”); Henry v. CorpCar Servs. Hous., Ltd. , 625 F. App’x 607, 611, 613 (5th Cir. 2015) (concluding that although the alleged harassment was brief as it had occurred over only two days, a jury could find that it was sufficiently severe to create a hostile work environment where, among other things, African American employees were compared to gorillas); see also Green v. Franklin Nat’l Bank of Minneapolis , 459 F.3d 903, 911 (8th Cir. 2006) (agreeing with the plaintiff that using the term “monkey” to refer to African Americans was “roughly equivalent” to using the term “n **** r”); Spriggs v. Diamond Auto Glass , 242 F.3d 179, 185 (4th Cir. 2001) (stating that use of “monkey” to describe African Americans was “degrading and humiliating in the extreme”).

175 In Burlington Industries, Inc. v. Ellerth, the Court explained that unfulfilled threats are actionable if they create a hostile work environment. 524 U.S. 742, 754 (1998) . A sufficiently serious threat, even if unfulfilled, could meet the necessary level of severity. See Schiano v. Quality Payroll Sys., Inc. , 445 F.3d 597, 607 (2d Cir. 2006) (“Threats or insinuations that employment benefits will be denied based on sexual favors are, in most circumstances, quintessential grounds for sexual harassment claims, and their characterization as ‘occasional’ will not necessarily exempt them from the scope of Title VII.”); Jansen v. Packaging Corp. of Am. , 123 F.3d 490, 500 (7th Cir. 1997) (en banc) (Flaum, J., concurring) (stating that a supervisor’s unambiguous communication that an adverse job action will follow if sexual favors are denied may cause “real emotional strife,” including “anxiety, distress, and loss of productivity regardless of whether the threat is carried out”).

176 See Woods v. Cantrell , 29 F.4th 284, 285 (5th Cir. 2022) (“The incident Woods has pleaded—that his supervisor directly called him a ‘Lazy Monkey A__ N___’ in front of his fellow employees—states an actionable claim of hostile work environment.”); Castleberry v. STI Grp. , 863 F.3d 259, 264 (3d Cir. 2017); Rodgers v. W.-S. Life Ins. Co. , 12 F.3d 668, 675 (7th Cir. 1993) (“Perhaps no single act can more quickly ‘alter the conditions of employment . . .’ than the use of an unambiguously racial epithet such as ‘n****r’ by a supervisor in the presence of his subordinates.” (citation omitted)); see also Ayissi-Etoh v. Fannie Mae , 712 F.3d 572, 580 (D.C. Cir. 2013) (Kavanaugh, J., concurring) (“[I]n my view, being called the n-word by a supervisor . . . suffices by itself to establish a racially hostile work environment. That epithet has been labeled, variously, a term that ‘sums up . . . all the bitter years of insult and struggle in America,’ ‘pure anathema to African-Americans,’ and ‘probably the most offensive word in English.’” (citations omitted)).

177 Burns v. McGregor Elec. Indus., Inc. , 989 F.2d 959, 965 (8th Cir. 1993) (quoting Katz v. Dole , 709 F.2d 251, 254 (4th Cir. 1983)); see also, e.g. , Johnson v. PRIDE Indus. , 7 F.4th 392, 403-04 (5th Cir. 2021) (holding that the plaintiff could establish a hostile work environment based on harassment that included the use of “mayate,” which the plaintiff knew was Spanish for the n-word, by a fellow employee who outranked him); Passananti v. Cook Cnty. , 689 F.3d 655, 665 (7th Cir. 2012) (“A raft of case law . . . establishes that the use of sexually degrading, gender-specific epithets, such as ‘sl*t,’ ‘c*nt,’ ‘wh*re,’ and ‘b*tch,’ . . . has been consistently held to constitute harassment based upon sex.” (quoting Forrest v. Brinker Int’l Payroll Co. , 511 F.3d 225, 229-30 (1st Cir. 2007))); Hawkins v. City of Phila. , 571 F. Supp. 3d 455, 464 (E.D. Pa. 2021) (“The term ‘f***ot’ is so replete with homophobic animus that, if used, instantly separates an individual who identifies as gay from everyone else in the workplace.”); Johnson v. Earth Angels , 125 F. Supp. 3d 562, 569 (M.D.N.C. 2015) (stating that racial epithets used by supervisors went “far beyond the merely unflattering” and were “degrading and humiliating in the extreme” (quoting Boyer-Liberto , 786 F.3d at 280)).

178 See, e.g. , Zetwick v. Cnty. of Yolo, 850 F.3d 436, 439, 442-46 (9th Cir. 2017) (concluding that a reasonable jury could find that the plaintiff was subjected to a hostile work environment where her supervisor greeted her with “at least a hundred” “unwelcome hugs and at least one unwelcome kiss” over a twelve-year period); Hall v. City of Chi. , 713 F.3d 325, 332 (7th Cir. 2013) (“[I]ncidents, which viewed in isolation seem relatively minor, that consistently or systematically burden women throughout their employment are sufficiently pervasive to make out a [sex-based] hostile work environment claim.”); EEOC v. Prospect Airport Servs., Inc. , 621 F.3d 991, 998-1001 (9th Cir. 2010) (determining that a genuine issue of material fact existed as to the abusiveness of the complainant’s work environment where, after the complainant twice rejected his coworker’s advances, this coworker and other coworkers subjected the complainant to six months of constant sexual pressure and humiliation); Lauderdale v. Tex. Dep’t of Crim. Just. , 512 F.3d 157, 163-64 (5th Cir. 2007) (concluding that a reasonable jury could find that the supervisor engaged in “pervasive harassment” where, among other things, he called the plaintiff “ten to fifteen times a night for almost four months”).

179 See supra note 150 and accompanying text.

180 See, e.g. , Rodgers , 12 F.3d at 674 (stating that liability is evaluated “on a case-by-case basis after considering the totality of the circumstances” (quoting Nazaire v. Trans World Airlines, Inc. , 807 F.2d 1372, 1380-81 (7th Cir. 1986))); McGullam v. Cedar Graphics, Inc. , 609 F.3d 70, 77 (2d Cir. 2010) (stating that “flexibility is useful in a context as fact-specific and sensitive as employment discrimination and as amorphous as hostile work environment”).

181 See, e.g. , El-Hakem v. BJY, Inc. , 415 F.3d 1068, 1073-74 (9th Cir. 2005) (upholding jury verdict for the plaintiff, noting that the CEO’s intentional and repeated use of a “Westernized” version of the plaintiff’s name, despite his objections, may not have been severe but was frequent and pervasive).

182 See Gorzynski v. JetBlue Airways Corp. , 596 F.3d 93, 103 (2d Cir. 2010) (concluding that, given the short time frame and number of incidents involved, the plaintiff established a genuine issue as to whether she was subjected to a hostile work environment).

183 This example is adapted from the facts in EEOC v. Prospect Airport Services, Inc. , 621 F.3d 991 (9th Cir. 2010).

184 This example is adapted from the facts in Broderick v. Ruder , 685 F. Supp. 1269, 1278 (D.D.C. 1988) (holding that the plaintiff stated a prima facie case of sexual harassment based on evidence that managers harassed female employees by bestowing preferential treatment on those who submitted to sexual advances).

185 Oncale v. Sundowner Offshore Servs., Inc. , 523 U.S. 75, 81 (1998).

186 Id. at 81-82; see also Reeves v. C.H. Robinson Worldwide , Inc. , 594 F.3d 798, 811 (11th Cir. 2010) (en banc) (stating that the analysis requires proceeding with “‘[c]ommon sense, and an appropriate sensitivity to social context,’ to distinguish between general office vulgarity and the ‘conduct which a reasonable person in the plaintiff’s position would find severely hostile or abusive’” (quoting Oncale , 523 U.S. at 82)); Hood v. Nat’l R.R. Passenger Corp. , 72 F. Supp. 3d 888, 893 (N.D. Ill. 2014) (stating that the joking manner in which the challenged comments were made was a relevant consideration in evaluating the severity of Hispanic employees’ use of “gringo” to refer to the White complainant).

187 Oncale, 523 U.S. at 82.

188 See McGinest v. GTE Serv. Corp. , 360 F.3d 1103, 1116 (9th Cir. 2004) (“Racially motivated comments or actions may appear innocent or only mildly offensive to one who is not a member of the targeted group, but in reality be intolerably abusive or threatening when understood from the perspective of a plaintiff who is a member of the targeted group. . . . By considering both the existence and the severity of discrimination from the perspective of a reasonable person of the plaintiff’s race, we recognize forms of discrimination that are real and hurtful, and yet may be overlooked if considered solely from the perspective of an adjudicator belonging to a different group than the plaintiff.”); see also Caver v. City of Trenton , 420 F.3d 243, 262 (3d Cir. 2005) (stating that a hostile work environment requires evidence establishing that the harassment would have adversely affected a reasonable person of the same protected class in the plaintiff’s position), abrogated on other grounds by Jensen v. Potter , 435 F.3d 444, 449 n.3 (3d Cir. 2006); Brennan v. Metro. Opera Ass’n, Inc. , 192 F.3d 310, 321 (2d Cir. 1999) (Newman, J., concurring in part and dissenting in part) (noting that the failure to adopt the perspective of the complainant’s protected class might result in applying the stereotypical views that Title VII was designed to outlaw); Torres v. Pisano , 116 F.3d 625, 632 (2d Cir. 1997) (evaluating the sexual harassment claim of a female plaintiff from the viewpoint of a “reasonable woman”); cf. Baugham v. Battered Women, Inc. , 211 F. App’x 432, 438 (6th Cir. 2006) (stating that the severity of harassment is evaluated from the “perspective of a reasonable person in the employee’s shoes, considering the totality of the circumstances” (citing Oncale , 523 U.S. at 81)).

189 See McGullam v. Cedar Graphics, Inc. , 609 F.3d 70, 85 (2d Cir. 2010) (Calabresi, J., concurring) (stating that the female complainant could base her hostile work environment claim on sexually derogatory conduct that was the product of locker room culture that some other women participated in); Gallagher v. C.H. Robinson Worldwide, Inc. , 567 F.3d 263, 272 n.2 (6th Cir. 2009) (concluding that the plaintiff established that she experienced sex-based harassment, even though some women participated in the conduct); Jenson v. Eveleth Taconite Co ., 824 F. Supp. 847, 886 (D. Minn. 1993) (concluding that expert testimony and testimony of female mine workers established that the work environment affected the psychological well-being of a reasonable woman working there, and this conclusion was not affected by the fact that some women did not find the work environment objectionable); Robinson v. Jacksonville Shipyards, Inc. , 760 F. Supp. 1486, 1525 (M.D. Fla. 1991) (stating that the fact that some women did not find the conduct offensive did not mean that the conduct was not objectively hostile).

190 Jenkins v. Univ. of Minn. , 838 F.3d 938, 946 (8th Cir. 2016) (doctoral candidate’s physical well-being in a remote location and academic future was dependent on a leading expert in the candidate’s field of study who harassed her on a research trip).

191 See EEOC v. Mgmt. Hosp. of Racine, Inc., 666 F.3d 422, 429, 433 (7th Cir. 2012) (stating that the ten-year age disparity between the teenage complainant and the older harasser, coupled with his authority over her, could have led a rational jury to conclude that the harassment resulted in a hostile work environment).

192 Cf. Rivera v. NIBCO, Inc., 364 F.3d 1057, 1064-65 (9th Cir. 2004) (“ While documented workers face the possibility of retaliatory discharge for an assertion of their labor and civil rights, undocumented workers confront the harsher reality that, in addition to possible discharge, their employer will likely report them to [immigration authorities] and they will be subjected to deportation proceedings or criminal prosecution. . . . As a result, most undocumented workers are reluctant to report abusive or discriminatory employment practices.”).

193 Prettyman v. LTF Club Opers. Co. , No. 1:18-cv-122, 2018 WL 5980512, at *6 (E.D. Va. Nov. 13, 2018) (“Much of this historical antipathy toward Jews was grounded in economic antisemitism, which makes comments about ‘Jewish money’ all the more objectionable and offensive. These words and phrases about Jews, like the n-word, are so serious and severe that they instantly signal to an employee that he or she is unwelcome in the work place because of his or her religion.”).

194 See EEOC v. Glob. Horizons, Inc. , 7 F. Supp. 3d 1053, 1061 (D. Haw. 2014) (threats of deportation contributed to a hostile work environment); Chellen v. John Pickle Co., Inc. , 446 F. Supp. 2d 1247, 1265 (N.D. Okla. 2006) (“The threat of deportation was especially significant in defendants’ creation of a hostile working environment. The Chellen plaintiffs feared . . . the harm he could inflict on [them] or their families if they were made to return to India.”).

195 This example is adapted from the facts in Doe v. Triangle Doughnuts, LLC , 472 F. Supp. 3d 115 (E.D. Pa. 2020).

196 See, e.g. , Copeland v. Ga. Dep’t of Corr. , ___ F.4th ___, No. 22-13073, 2024 WL 1316677, at *8 (11th Cir. Mar. 28, 2024) (concluding that working as a corrections officer, which is a “dangerous and sometimes” violent context, made the intentional misgendering and other harassment that a transgender male correctional officer experienced more severe than it would have been in other contexts); Jenkins v. Univ. of Minn. , 838 F.3d 938, 946 (8th Cir. 2016) (concluding that the alleged harassment was sufficient to establish a hostile work environment where, among other things, the plaintiff and the alleged harasser worked in a remote region where they had been dropped by plane).

197 See EEOC v. Sunbelt Rentals, Inc. , 521 F.3d 306, 318 (4th Cir. 2008) (rejecting the district court’s suggestion that harassment might be discounted in an environment that was “inherently coarse”; “Title VII contains no such ‘crude environment’ exception, and to read one into it might vitiate statutory safeguards for those who need them most”); see also Reeves v. C.H. Robinson Worldwide , 594 F.3d 798, 810 (11th Cir. 2010) (en banc) (stating that a “member of a protected group cannot be forced to endure pervasive, derogatory conduct and references that are gender-specific in the workplace, just because the workplace may be otherwise rife with generally indiscriminate vulgar conduct”); Jackson v. Quanex Corp. , 191 F.3d 647, 662 (6th Cir. 1999) (“[W]e squarely denounce the notion that the increasing regularity of racial slurs and graffiti renders such conduct acceptable, normal, or part of ‘conventional conditions on the factory floor.’”); Vollmar v. SPS Techs., LLC , No. 15-2087, 2016 WL 7034696, at *6 (E.D. Pa. Dec. 2, 2016) (concluding that even in a work environment in which foul language and joking are commonplace, the employer can be liable for fostering a hostile work environment for female employees).

198 Smith v. Sheahan, 189 F.3d 529, 535 (7th Cir. 1999); see also Reeves , 594 F.3d at 803, 812-13 (holding that the plaintiff, the only woman working on the sales floor, could establish a sexually hostile work environment based on vulgar, sex-based conduct, even though the conduct had begun before she entered the workplace); Williams v. Gen. Motors Corp. , 187 F.3d 553, 564 (6th Cir. 1999) (“We do not believe that a woman who chooses to work in the male-dominated trades relinquishes her right to be free from sexual harassment . . . .”); Rabidue v. Osceola Refining Co. , 805 F.2d 611, 626 (6th Cir. 1986) (Keith, J., concurring in part, dissenting in part) (stating that a female employee should not have to assume the risk of a hostile work environment by voluntarily entering a workplace in which sexual conduct abounds); Walker v. Ford Motor Co. , 684 F.2d 1355, 1359 (11th Cir. 1982) (rejecting the contention that racial epithets that were common in the defendant’s industry could not establish a hostile work environment based on race).

199 See, e.g. , Reeves , 594 F.3d at 811-12 (concluding that a reasonable jury could find that the conduct in the plaintiff’s office, including use of the terms “wh*re,” “b*tch,” and “c*nt,; vulgar discussions of women’s body parts; and the pornographic image of a woman in the office, contributed to conditions that were humiliating and degrading to women on account of their sex and thus could have created an abusive working environment).

200 Although evidence of unwelcomeness may be relevant, the Commission does not believe that a plaintiff needs to prove “unwelcomeness” as a separate element of the prima facie case. See supra section III.B.1.

201 Compare Souther v. Posen Constr., Inc. , 523 F. App’x 352, 355 (6th Cir. 2013) (concluding that a jury could not find that the alleged harasser’s sexual advances were unwelcome where, among other things, the plaintiff and alleged harasser were engaged in an on-and-off sexual relationship for five years, she never complained to the alleged harasser or anyone else that his conduct was unwelcome, and the plaintiff and alleged harasser remained friends during the period when the affair was dormant), with Williams v. Herron , 687 F.3d 971, 975 (8th Cir. 2012) (concluding that a correctional officer presented sufficient evidence to show that she adequately communicated to the chief deputy that his conduct was unwelcome where she told him that she was uncomfortable continuing their relationship and that she was concerned that she would lose her job if she ended their relationship, given that she knew that other female employees were fired after ending their relationships with him), Pérez-Cordero v. Wal-Mart P.R., Inc. , 656 F.3d 19, 28 (1st Cir. 2011) (concluding that the plaintiff established that his supervisor’s conduct was unwelcome where, among other things, the plaintiff twice unequivocally rejected his supervisor’s sexual propositions), and EEOC v. Prospect Airport Servs., Inc. , 621 F.3d 991, 998 (9th Cir. 2010) (concluding that the plaintiff established a fact issue regarding whether conduct was unwelcome where he repeatedly told his coworker, “I’m not interested,” yet she continued to make sexual overtures).

202 See Webb-Edwards v. Orange Cnty. Sheriff’s Off. , 525 F.3d 1013, 1027-28 (11th Cir. 2008) (concluding that the plaintiff failed to demonstrate that the harasser’s conduct was severe or pervasive, in part because the conduct ended after the plaintiff told the harasser that it made her uncomfortable); Shanoff v. Ill. Dep’t of Hum. Servs. , 258 F.3d 696, 704 (7th Cir. 2001) (stating that repeated harassment that continues despite an employee’s objections is indicative of a hostile work environment); Moore v. Pool Corp ., 304 F. Supp. 3d 1148, 1160 (N.D. Ala. 2018) (concluding that a jury could conclude that alleged racial harassment by a customer was objectively hostile, where the customer not only called the plaintiff a “n****r” five to seven times a year over several years, but the customer continued the harassment even after the plaintiff objected and asked the customer to stop using the racial epithet).

203 See, e.g. , Christian v. Umpqua Bank , 984 F.3d 801, 806-07, 811 (9th Cir. 2020) (concluding that the evidence created a triable issue as to whether a customer’s harassment of the complainant was sufficiently severe or pervasive where the customer persisted in asking the complainant on dates, sending her notes and letters, and repeatedly “pester[ing] her” for months after the complainant asked him to stop).

204 See EEOC, Compliance Manual Section 12: Religious Discrimination § 12‑III.B.2.b (2021), https://www.eeoc.gov/laws/guidance/section-12-religious-discrimination#_Toc203359509 ; Venters v. City of Delphi , 123 F.3d 956, 976 (7th Cir. 1997) (concluding that a reasonable person in the plaintiff’s position could have found the work environment hostile where the supervisor’s remarks were uninvited, intrusive, and continued even after the employee informed her supervisor that his comments were inappropriate).

205 See Garcimonde-Fisher v. Area203 Mktg., LLC , 105 F. Supp. 3d 825, 840 (E.D. Tenn. 2015) (“The references to the King James Bible as the proper Bible and to Catholicism as not the ‘right kind’ of Christianity could fairly be described as derogatory. While these comments may not be as overtly hostile as depicting a coworker as a satanic figure, they do serve to reinforce the omnipresent message of the workplace that [one] religion is the only religion that will be tolerated.”).

206 Nat’l R.R. Passenger Corp. v. Morgan , 536 U.S. 101, 117-18 (2002) (explaining that because a hostile work environment is a single unlawful employment action, a court should not separate individual acts that are part of the broader claim when analyzing timeliness or liability).

207 Morgan , 536 U.S. at 120. Compare Ford v. Jackson Nat’l Life Ins. Co., 45 F.4th 1202, 1228-29 (10th Cir. 2022) (holding that a pre-filing-period incident in which a manager had engaged in sexually suggestive conduct with a vodka bottle was part of the same hostile work environment as subsequent conduct by other workers that demonstrated “the same type of sex-based hostility that [the plaintiff] ha[d] repeatedly complained of”), Maliniak v. City of Tucson , 607 F. App’x 626, 628 (9th Cir. 2015) (concluding that an offensive sign posted within the 300-day charge-filing time period was sufficiently related to the offensive signs that pre-dated the charge-filing period to be considered part of the same actionable hostile work environment claim, where both sets of signs denigrated women), Mandel v. M & Q Packaging Corp. , 706 F.3d 157, 165-67 (3d Cir. 2013) (concluding that the plaintiff could proceed with her hostile work environment claim under Morgan ’s single unlawful employment practice theory where at least one incident—being called a “b*tch” during a meeting—occurred within the charge-filing period and many of the acts that fell outside the filing period involved similar conduct by the same individuals), and EEOC v. Fred Meyer Stores, Inc. , 954 F. Supp. 2d 1104, 1121-23 (D. Or. 2013) (concluding that sexual harassment of a retail store employee by a customer that occurred before the employee’s six-month absence could be considered along with harassment that occurred after she returned in determining whether she was subjected to a hostile work environment, where the conduct involved the same customer engaging in similar physical harassment before and after the employee’s absence from the workplace, and despite the employee’s complaint, the harasser was allowed to continue frequenting the store before he sexually harassed her again), with Martinez v. Sw. Cheese Co., LLC , 618 F. App’x 349, 354 (10th Cir. 2015) (holding that pre-filing period conduct was not sufficiently related to filing period conduct so as to be part of the same hostile work environment where it did not involve the same type of conduct, it occurred infrequently, and it involved different harassers), and Lucas v. Chi. Transit Auth. , 367 F.3d 714, 727 (7th Cir. 2004) (holding that an incident that occurred within the charge-filing time period was not part of the same hostile work environment as the earlier incidents where there was a three-year gap and the last incident involved a chance encounter on a commuter train).

208 See Morgan , 536 U.S. at 120-21 (affirming lower court’s ruling that acts were part of the same actionable hostile environment claim where they involved “the same type of employment actions, occurred relatively frequently, and were perpetrated by the same managers”); see also McGullam v. Cedar Graphics, Inc. , 609 F.3d 70, 77 (2d Cir. 2010) (stating that “ Morgan requires courts to make an individualized assessment of whether incidents and episodes are related” without limiting the relevant criteria or imposing particular factors, and stating that “[t]his flexibility is useful in a context as fact-specific and sensitive as employment discrimination and as amorphous as hostile work environment”).

209 See King v. Aramark Servs., Inc. , 96 F.4th 546, 561 (2d Cir. 2024) (“A discrete discriminatory act, such as termination, within the limitations period may not only support a claim for damages, it may also render a hostile work environment claim timely if it is shown to be part of the course of discriminatory conduct that underlies the hostile work environment claim .” (emphasis in original)); Baird v. Gotbaum , 662 F.3d 1246, 1251-52 (D.C. Cir. 2011) (holding that the district court erred in concluding that the plaintiff’s hostile work environment claim could not include discrete acts that also were actionable on their own); Chambless v. La.-Pac. Corp. , 481 F.3d 1345, 1350 (11th Cir. 2007) (concluding that, although a timely discrete act can provide a basis for considering untimely, non-discrete acts as part of the same hostile work environment claim, the timely failure to promote and retaliation were not sufficiently similar to untimely allegations so as to be part of the same hostile work environment claim); Royal v. Potter , 416 F. Supp. 2d 442, 453-54 (S.D. W. Va. 2006) (concluding that the plaintiff’s actionable hostile work environment claim included termination of a temporary position and failure to promote). But see Porter v. Cal. Dep’t of Corr. , 419 F.3d 885, 892-93 (9th Cir. 2005) (stating that timely acts offered in support of a hostile work environment claim must be non-discrete acts because basing a hostile work environment claim on timely discrete and untimely non-discrete acts would “blur to the point of oblivion the dichotomy between discrete acts and a hostile environment”).

As discussed in the EEOC’s Compliance Manual section on threshold issues: “[A] discrete act of discrimination [an official act that is independently actionable] may be part of a hostile work environment only if it is related to abusive conduct or language, i.e., a pattern of discriminatory intimidation, ridicule, and insult. A discrete act that is unrelated to abusive conduct or language ordinarily would not support a hostile work environment claim.” EEOC, Compliance Manual Section 2: Threshold Issues § 2-IV.C.1.b (2009), https://www.eeoc.gov/laws/guidance/section-2-threshold-issues#2-IV-C-1-b https://www.eeoc.gov/policy/docs/threshold.html#2-IV-C-1-b; see also Bearer v. Teva Pharms. USA, Inc. , No. 19-5415, 2021 WL 4145053, at *24 (E.D. Pa. Sept. 8, 2021) (stating that “failure to be promoted, without any indication that it is connected to hostile or abusive behavior, is simply not a form of harassment that can contribute to a hostile work environment”).

210 This example is adapted from the facts in Isaacs v. Hill’s Pet Nutrition, Inc. , 485 F.3d 383, 385-87 (7th Cir. 2007).

211 This example is adapted from the facts in McGullam , 609 F.3d at 72-74.

212 See note 166 and accompanying text.

213 See Reeves v. C.H. Robinson Worldwide, Inc. , 594 F.3d 798, 803, 811-12 (11th Cir. 2010) (en banc) (concluding that a jury could find that the conduct of male sales floor employee that was sex-specific, derogatory, and humiliating—including vulgar sexual comments, pornographic images of women, and sex-based epithets—created a hostile work environment for the complainant, who was the only woman on the sales floor, even though the conduct was not specifically directed at her); cf. Robinson v. Jacksonville Shipyards, Inc. , 760 F. Supp. 1486, 1523 (M.D. Fla. 1991) (stating that pornography “sexualizes the work environment to the detriment of all female employees”).

214 See, e.g. , Tademy v. Union Pac. Corp. , 614 F.3d 1132, 1144-46 (10th Cir. 2008) (holding that a reasonable jury could conclude that the plaintiff was subjected to a racially hostile work environment, which included anonymous bathroom graffiti and the display of a noose); see also Rasmy v. Marriott Int’l, Inc. , 952 F.3d 379, 388-89 (2d Cir. 2020) (concluding that the complainant raised disputed issues of material fact as to whether a coworker’s comments about religion and the complainant’s national origin, which were not directed at the complainant but made to others in his presence, contributed to a hostile work environment).

215 See, e.g. , Ellis v. Houston , 742 F.3d 307, 320-21 (8th Cir. 2014) (concluding that the district court erred in evaluating the plaintiffs’ § 1981 and § 1983 racial harassment claims by examining in isolation harassment personally experienced by each plaintiff, rather than also considering conduct directed at others, where every plaintiff did not hear every remark but each plaintiff became aware of all of the conduct); Adams v. Austal, U.S.A., LLC , 754 F.3d 1240, 1257-58 (11th Cir. 2014) (stating that employees could base their racial harassment claims on conduct that they were aware of); Hawkins v. Anheuser-Busch, Inc. , 517 F.3d 321, 335-36 (6th Cir. 2008) (concluding that evidence of a hostile work environment may include acts of harassment that the plaintiff becomes aware of during her employment that were directed at others and occurred outside her presence).

216 This example is adapted from the facts in Rodgers v. Western-Southern Life Ins. Co. , 12 F.3d 668, 670-72 (7th Cir. 1993).

217 See Thompson v. N. Am. Stainless, LP , 562 U.S. 170, 177-78 (2011) (holding that Title VII does not merely authorize suit by someone who was allegedly discriminated against but instead more broadly authorizes suit by anyone who falls within the zone of interests protected by Title VII, meaning “any plaintiff with an interest ‘arguably [sought] to be protected by the statute’” (quoting Nat’l Credit Union Admin. v. First Nat. Bank & Trust Co. , 522 U.S. 479, 495 (1998)); and further holding that, pursuant to that test, Thompson could bring a lawsuit alleging North American Stainless (NAS) fired him to retaliate against his fiancée, who had filed a sex discrimination charge against NAS, because “the purpose of Title VII is to protect employees from their employers’ unlawful actions[, and] injuring him was the employer’s intended means of harming [his fiancée]”); cf. Finn v. Kent Sec. Servs., Inc ., 981 F. Supp. 2d 1293, 1300 (S.D. Fla. 2013) (concluding that a plaintiff might have standing to pursue a claim if the Defendant “required her, as part of her duties, to serve as the delivery vehicle of Defendant’s discrimination against other employees based on their race, sex, or color”).

218 Sophie also could file an EEOC charge alleging that she was subjected to unlawful retaliation based on Jordan’s threats in response to her objection to the harassment. For more information on what constitutes unlawful retaliation, see EEOC, Enforcement Guidance on Retaliation and Related Issues § II.A.2 (2016), https://www.eeoc.gov/laws/guidance/enforcement-guidance-retaliation-and-related-issues#2._Opposition .

219 See, e.g. , Nichols v. Tri-Nat’l Logistics, Inc. , 809 F.3d 981, 985-86 (8th Cir. 2016) (holding that the district court erred in analyzing a hostile work environment claim by the plaintiff, a truck driver, by excluding alleged sexual harassment of the plaintiff by her driving partner during a mandatory rest period); Little v. Windermere Relocation, Inc. , 301 F.3d 958, 967 (9th Cir. 2002) (concluding that a potential client’s rape of a female manager at a business meeting outside her workplace was sufficient to establish a hostile work environment since having out-of-office meetings with potential clients was a job requirement); Ferris v. Delta Air Lines, Inc. , 277 F.3d 128, 135 (2d Cir. 2001) (concluding that the “work environment” included a short layover for flight attendants in a foreign country where the employer provided a block of hotel rooms and ground transportation).

220 See Lapka v. Chertoff , 517 F.3d 974, 979, 983 (7th Cir. 2008) (concluding that Title VII covered sexual harassment that occurred while attending employer-mandated training at an out-of-state training center).

221 See Blakey v. Cont’l Airlines, Inc. , 751 A.2d 538, 543 (N.J. 2000) (concluding that, although the electronic bulletin board did not have a physical location at the employee’s worksite, evidence might show it was so closely related to the workplace environment and beneficial to the employer that continuation of harassment on it should be regarded as occurring in the workplace).

222 See Meritor Sav. Bank, FSB v. Vinson, 477 U.S. 57, 60 (1986) (noting that an employee had alleged harassment by her supervisor, which included conduct both inside and outside the workplace and conduct both during and after business hours).

223 See, e.g. , Lapka , 517 F.3d at 983 (explaining that, to be actionable, harassment need only have consequences in the workplace); Crowley v. L.L. Bean, Inc. , 303 F.3d 387, 409-10 (1st Cir. 2002) (stating that the harasser’s intimidating conduct outside the workplace helped show why the complainant feared him and why his presence around her at work created a hostile work environment); Duggins v. Steak ‘n Shake, Inc. , 3 F. App’x 302, 311 (6th Cir. 2001) (stating that an employee may reasonably perceive her work environment as hostile if forced to work for, or in close proximity to, someone who harassed her outside the workplace); cf. Andersen v. Rochester City Sch. Dist. , 481 F. App’x 628, 630 (2d Cir. 2012) (concluding that alleged harassment of a teacher by a student outside of school did not create a hostile work environment where the student was not in the teacher’s class and they did not interact at school).

224 See, e.g., Strickland v. City of Detroit , 995 F.3d 495, 506-07 (6th Cir. 2021) (considering social media posts by police department personnel referring to Detroit residents as “garbage” and characterizing Black Lives Matter supporters as “racist terrorists” in assessing whether the plaintiff’s work environment was sufficiently racially hostile to be actionable); Fisher v. Mermaid Manor Home for Adults, LLC , 192 F. Supp. 3d 323, 326, 329 (E.D.N.Y. 2016) (determining that a reasonable jury could find that a coworker’s Instagram post, brought to the plaintiff’s attention by two other coworkers, which compared the plaintiff to a chimpanzee character in the Planet of the Apes movie, created a hostile work environment); Tammy S. v. Dep’t of Def., EEOC Appeal No. 0120084008, 2014 WL 2647178, at *12 (June 6, 2014) (concluding that the complainant was subjected to sex-based harassment creating a hostile work environment, including by way of postings on the harasser’s personal website, which were announced during a training class at work and were viewed and discussed by many employees in the workplace); Knowlton v. Dep’t of Transp., EEOC Appeal No. 0120121642, 2012 WL 2356829, at *1-3 (June 15, 2012) (reversing dismissal of a harassment claim that included a race-related comment posted by a coworker on Facebook).

225 This example is adapted from the facts in Fisher , 192 F. Supp. 3d at 326-27.

226 See Abbt v. City of Hous. , 28 F.4th 601, 609 (5th Cir. 2022) (concluding that a reasonable jury could find that the plaintiff, a firefighter, was subjected to a sex-based hostile work environment arising from her colleagues’ repeated viewing of a private, nude, intimate video that she had made for her husband).

227 See, e.g. , EEOC v. Fairbrook Med. Clinic, P.A., 609 F.3d 320, 329 (4th Cir. 2010) (stating that the severity of the harasser’s conduct was exacerbated by his significant authority over the complainant).

228 See Burlington Indus., Inc. v. Ellerth , 524 U.S. 742, 760-62 (1998) (noting “[a]s a general proposition, only a supervisor, or other person acting with the authority of the company, can cause this sort of injury”).

229 Id. at 759 (“Negligence sets a minimum standard for employer liability under Title VII.”).

230 Id. at 758 (stating that negligence and vicarious liability, as set forth in provisions of the Restatement (Second) of Agency, “are possible grounds for imposing employer liability on account of a supervisor’s acts and must be considered”); see also id. at 759 (“Thus, although a supervisor’s sexual harassment is outside the scope of employment because the conduct was for personal motives, an employer can be liable, nonetheless, where its own negligence is a cause of the harassment.”); Debord v. Mercy Health Sys. of Kansas, Inc. , 737 F.3d 642, 650-55 (10th Cir. 2013) (analyzing harassment by a supervisor under both negligence and vicarious liability standards); Dees v. Johnson Controls World Servs., Inc. , 168 F.3d 417, 421-22 (11th Cir. 1999) (same).

231 Sharp v. City of Hous. , 164 F.3d 923, 929 (5th Cir. 1999) (“The concept of negligence thus imposes a minimum standard for employer liability—direct liability—under title VII, a standard that is supplemented by the agency-based standards for vicarious liability as articulated in Faragher and [ Ellerth ].” (internal quotation marks and citation omitted)); Wilson v. Tulsa Junior Coll. , 164 F.3d 534, 540 n.4 (10th Cir. 1998) (“The Supreme Court recognized in [ Ellerth ] and Faragher the continuing validity of negligence as a separate basis for employer liability.”).

232 Although negligence and vicarious liability are distinct grounds for employer liability for unlawful harassment by a supervisor, both standards look at the reasonableness of the employer’s actions. The D.C. Circuit has explained: “While the reasonableness of an employer’s response to sexual harassment is at issue under both standards, the plaintiff must clear a higher hurdle under the negligence standard, where she bears the burden of establishing her employer’s negligence, than under the vicarious liability standard, where the burden shifts to the employer to prove its own reasonableness and the plaintiff’s negligence.” Curry v. D.C. , 195 F.3d 654, 660 (D.C. Cir. 1999) (citing Shaw v. AutoZone, Inc. ,180 F.3d 806, 812 n.2 (7th Cir. 1999)).

233 For a discussion of how to determine whether conduct is part of the same hostile work environment claim, refer to section III.C.1, supra .

234 See Williams v. Gen. Motors Corp. , 187 F.3d 553, 562-63 (6th Cir. 1999); O’Rourke v. City of Providence , 235 F.3d 713, 736 (1st Cir. 2001).

235 See, e.g. , O’Brien v. Middle E. Forum , 57 F.4th 110, 120 (3d Cir. 2023); Townsend v. Benjamin Enters., Inc. , 679 F.3d 41, 54 (2d Cir. 2012); Helm v. Kansas , 656 F.3d 1277, 1286 (10th Cir. 2011); Ackel v. Nat’l Commc’ns, Inc. , 339 F.3d 376, 383 (5th Cir. 2003); Johnson v. West , 218 F.3d 725, 730 (7th Cir. 2000).

236 See, e.g. , Faragher v. City of Boca Raton , 524 U.S. 775, 789-90 (1998) (citing circuit court decisions recognizing appropriateness of proxy liability for harassment by individuals occupying such positions); Townsend , 679 F.3d at 54 (recognizing that employer liability is appropriate for harassment by individuals occupying these positions); Johnson , 218 F.3d at 730 (same); see also O’Brien , 54 F.4th at 121 (“We recognize, of course, that ‘only individuals with exceptional authority and control within an organization can meet’ this standard.” (quoting Helm , 656 F.3d at 1286)).

237 See Harrison v. Eddy Potash, Inc. , 158 F.3d 1371, 1376 (10th Cir. 1998) (stating that Faragher and Ellerth do not suggest that a supervisor can be considered the employer’s alter ego merely because he possesses a high degree of control over a subordinate); see also O’Brien , 57 F.4th at 121 (stating that “merely serving as a supervisor with some amount of control over a subordinate does not establish proxy status”); Townsend , 679 F.3d at 55-56 (concluding that a jury instruction was erroneous because it gave the misleading impression that mere status as a supervisor with power to hire and fire is sufficient to render the harasser the employer’s alter ego); Johnson , 218 F.3d at 730 (concluding that alter-ego liability did not apply where the supervisor was not a high-level manager whose actions spoke for the defendant).

238 Vance v. Ball State Univ., 570 U.S. 421, 424 (2013).

An employer cannot shield itself from liability by “concentrat[ing] all decisionmaking authority in a few individuals.” Id. at 446-47. As the Supreme Court has explained, when an employer attempts to “confine decisionmaking power to a small number of individuals,” those decisionmakers will likely still need to rely on input from “other workers who actually interact with the affected employee” and will have “a limited ability to exercise independent discretion when making decisions.” Id. at 447. Under those conditions, the employer has effectively delegated the authority to take tangible employment actions to the lower-level employees on whose input the formal decisionmakers must rely. Id. As a result, those lower-level employees will qualify as “supervisors.” See Velázquez-Pérez v. Developers Diversified Realty Corp. , 753 F.3d 265, 272 (1st Cir. 2014) (“As Vance recognizes, at some point the ability to provide advice and feedback may rise to the level of delegated authority sufficient to make someone a supervisor. . .”); see also Wyatt v. Nissan N. Am., Inc. , 999 F.3d 400, 416 (6th Cir. 2021) (concluding that a reasonable jury could find that the harasser was the plaintiff’s supervisor where there were genuine issues about whether the plaintiff’s formal supervisor effectively delegated supervisory power to and relied on recommendations from the harasser); Boyer-Liberto v. Fontainebleau Corp. , 786 F.3d 264, 280 (4th Cir. 2015) (en banc) (concluding that an individual whose recommendations “would be rubber-stamped” was the plaintiff’s supervisor).

239 Burlington Indus., Inc. v. Ellerth , 524 U.S. 742, 761-62 (1998).

As the Supreme Court has explained, Ellerth invoked the “tangible employment action” concept “only to ‘identify a class of [hostile work environment] cases’ in which an employer should be held vicariously liable (without an affirmative defense) for the acts of supervisors.” Burlington N. & Santa Fe Ry. Co. v. White , 548 U.S. 53, 64 (2006) (alteration in original) (quoting Ellerth , 524 U.S. at 760); see also Pa. State Police v. Suders , 542 U.S. 129, 143 (2004) (describing Ellerth and Faragher v. City of Boca Raton , 524 U.S. 775 (1998), as delineating two categories of hostile work environment claims distinguished by the presence or absence of a tangible employment action). Ellerth does not address the scope of either Title VII’s general antidiscrimination provision or Title VII’s anti-retaliation provision. Burlington N. , 548 U.S. at 65; see also Chambers v. District of Columbia , 35 F.4th 870, 875-76 (D.C. Cir. 2022) (en banc) (concluding that Ellerth did not provide grounds for an “objectively tangible harm” requirement under the general antidiscrimination provision).

240 E.g. , Ellerth , 524 U.S. at 761; Faragher , 524 U.S. at 790.

241 See Green v. Adm’rs of the Tulane Educ. Fund , 284 F.3d 642, 654-55 (5th Cir. 2002).

242 Kramer v. Wasatch Cnty. Sheriff’s Off. , 743 F.3d 726, 738 (10th Cir. 2014) (emphasis in original); id. at 741 (“Even if the [formal decision maker] undertook some independent analysis when considering employment decisions recommended by [the alleged harasser], [the alleged harasser] would qualify as a supervisor so long as his recommendations were among the proximate causes of the [formal decision maker’s] decision-making.” (emphasis in original)).

243 See Ellerth , 524 U.S. at 759 (“If, in the unusual case, it is alleged there is a false impression that the actor was a supervisor, when he in fact was not, the victim’s mistaken conclusion must be a reasonable one.”); Llampallas v. Mini-Circuits Lab, Inc. , 163 F.3d 1236, 1247 n.20 (11th Cir. 1998) (“Although the employer may argue that the employee had no actual authority to take the employment action against the plaintiff, apparent authority serves just as well to impute liability to the employer for the employee’s action.”). But see EEOC v. CRST Van Expedited, Inc. , 679 F.3d 657, 685 (8th Cir. 2012) (stating that apparent authority is insufficient to establish supervisor status and the imposition of vicarious liability).

244 In Kramer v. Wasatch County Sheriff’s Off. , the Tenth Circuit concluded that apparent-authority principles also might apply where an employer has vested an employee with some limited authority over the complainant and the complainant reasonably but mistakenly believes that the employee also has related powers, which, in some circumstances, might include the power to undertake or substantially influence tangible employment actions. 743 F.3d at 742-43.

245 See generally Kramer, 743 F.3d at 742 (“ Apparent authority exists where an entity ‘has created such an appearance of things that it causes a third party reasonably and prudently to believe that a second party has the power to act on behalf of the first [party].’” (quoting Bridgeport Firemen’s Sick & Death Benefits Ass’n v. Deseret Fed. Sav. & Loan Ass’n , 735 F.2d 383, 388 (10th Cir. 1984))); see also Restatement (Third) of Agency § 2.03 (2006) (defining “apparent authority” as the “power held by an agent or other actor to affect a principal’s legal relations with third parties when a third party reasonably believes the actor has authority to act on behalf of the principal and that belief is traceable to the principal’s manifestations”); id. § 3.03 (“Apparent authority, as defined in § 2.03, is created by a person’s manifestation that another has authority to act with legal consequences for the person who makes the manifestation, when a third party reasonably believes the actor to be authorized and the belief is traceable to the manifestation.”).

246 See, e.g. , Dunn v. Wash. Cnty. Hosp. , 429 F.3d 689, 691 (7th Cir. 2005).

247 See, e.g. , Watson v. Blue Circle, Inc. , 324 F.3d 1252, 1258 n.2 (11th Cir. 2003).

248 See, e.g. , Campbell v. Haw. Dep’t of Educ. , 892 F.3d 1005, 1017 (9th Cir. 2018).

249 See, e.g. , Chaney v. Plainfield Healthcare Ctr. , 612 F.3d 908, 914-15 (7th Cir. 2010).

250 See, e.g. , EEOC v. Cromer Food Servs., Inc. , 414 F. App’x 602, 606-07 (4th Cir. 2011) (collecting cases in which circuit courts have held employers may be liable for acts of harassment committed against employees by non-employees).

251 An employer’s duty to take reasonable corrective action to prevent harassment from continuing is discussed supra at section IV.C.3.b.

252 See Faragher v. City of Boca Raton , 524 U.S. 775, 789 (1998) (noting that employer liability for a hostile work environment has not been disputed when the harasser was “indisputably within that class of an employer organization’s officials who may be treated as the organization’s proxy”); O’Brien v. Middle E. Forum , 57 F.4th 110, 117 (3d Cir. 2023) (concluding that, pursuant to Faragher and Ellerth , the affirmative defense is unavailable when the individual who engaged in the alleged harassment was the employer’s proxy or alter ego); Townsend v. Benjamin Enters., Inc. , 679 F.3d 41, 52-53 (2d Cir. 2012) (same); Ackel v. Nat’l Commc’ns, Inc. , 339 F.3d 376, 383-84 (5th Cir. 2003) (same); Johnson v. West , 218 F.3d 725, 730 (7th Cir. 2000) (same).

253 As discussed in section IV.A, supra , an employer also may be liable for harassment by a supervisor pursuant to negligence principles.

254 Burlington Indus., Inc. v. Ellerth , 524 U.S. 742, 761-62 (1998). A “tangible employment action” means a “significant change in employment status” that requires an “official act” of the employer. Id .; see also supra section IV.B.2 (discussing the definition of “tangible employment action”).

255 Ellerth , 524 U.S. at 761-62.

256 Id. at 762; see also id. at 762-63 (explaining that requirements of the “aided in the agency” relation standard “will always be met when a supervisor takes a tangible employment action against a subordinate”).

257 As discussed in section III.C.1, supra , a discriminatory employment practice that occurred within the charge-filing period may be independently actionable regardless of whether it is also part of a hostile work environment claim.

258 See Faragher v. City of Boca Raton , 524 U.S. 775, 808 (1998) (holding no affirmative defense is available where a supervisor’s harassment culminates in a tangible employment action and providing examples of non-career-ending tangible employment actions to include demotion and undesirable reassignment); Ellerth , 524 U.S. at 761-63 (holding that vicarious liability will always be imputed to an employer when a supervisor takes a tangible employment action, which could include non-career-ending actions such as denial of raise or promotion); Llampallas v. Mini-Circuits, Inc. , 163 F.3d 1236, 1247 (11th Cir. 1998) (stating an inference arises that there is a causal link between the harasser’s discriminatory animus and the employment decision “ any time the harasser makes a tangible employment decision that adversely affects the plaintiff,” such as a demotion (emphasis added)); see also Ferraro v. Kellwood Co. , 440 F.3d 96, 101-02 (2d Cir. 2006) (stating that the affirmative defense is not available if a tangible employment action was taken against an employee as part of a supervisor’s discriminatory harassment and that harassment culminates in a tangible employment action if the action is “linked” to the harassment); cf. Cotton v. Cracker Barrel Old Country Store, Inc. , 434 F.3d 1227, 1232 (11th Cir. 2006) (stating that there must be a causal link between the tangible employment action, in this case an alleged reduction in hours, and the sexual harassment, which can be shown by temporal proximity).

259 Under such circumstances, the employee also would have a claim that the denial of a raise was because of sex. See supra section III.C.1 (noting that conduct that is separately actionable also may be part of a hostile work environment claim).

260 See Baldwin v. Blue Cross/Blue Shield of Ala. , 480 F.3d 1287, 1303 (11th Cir. 2007) (stating that the affirmative defense is not available where “the discrimination the employee has suffered included a tangible employment action”).

261 See Ellerth , 524 U.S. at 754 (analyzing harassment claim as a hostile work environment claim because it involved only unfulfilled threats); Henthorn v. Capitol Commc’ns, Inc. , 359 F.3d 1021, 1027 (8th Cir. 2004) (analyzing an unfulfilled implied threat as a factor in determining whether the plaintiff was subjected to a hostile work environment).

262 See Holly D. v. Cal. Inst. of Tech. , 339 F.3d 1158, 1169 (9th Cir. 2003) (concluding that “determining not to fire an employee who has been threatened with discharge constitutes a ‘tangible employment action,’ at least where the reason for the change in the employment decision is that the employee has submitted to coercive sexual demands”); Jin v. Metro. Life Ins. Co., 310 F.3d 84, 98 (2d Cir. 2002) (finding prejudicial error where the lower court failed to instruct the jury to consider the supervisor’s conditioning of the plaintiff’s continued employment on her submission to his sexual demands as a possible tangible employment action ). But see Santiero v. Denny’s Rest. Store , 786 F. Supp. 2d 1228, 1235 (S.D. Tex. 2011) (concluding that the employee was not subjected to a tangible employment action where she acceded to sexual demands and thereby avoided a tangible employment action); Speaks v. City of Lakeland , 315 F. Supp. 2d 1217, 1224-26 (M.D. Fla. 2004) (rejecting the Jin analysis as inconsistent with Supreme Court and Eleventh Circuit precedent).

263 Faragher , 524 U.S. at 807; Ellerth , 524 U.S. at 765.

264 Ellerth , 524 U.S. at 764.

265 Id . at 765 (emphasis added); Faragher , 524 U.S. at 807 (emphasis added); see also, e.g. , Frederick v. Sprint/United Mgmt. Co. , 246 F.3d 1305, 1313 (11th Cir. 2001) (“Both elements must be satisfied for the defendant-employer to avoid liability, and the defendant bears the burden of proof on both elements.”).

266 Ellerth , 524 U.S. at 765.

267 If the employer had been aware of previous harassment by the same supervisor, then the employer would not be able to establish the affirmative defense if it had failed to take appropriate corrective action in the past to address harassment by that supervisor. See Minarsky v. Susquehanna Cnty ., 895 F.3d 303, 312-13 (3d Cir. 2018) (holding that a jury could find that the employer did not act reasonably to prevent harassment by the plaintiff’s supervisor where county officials were aware that the supervisor’s conduct “formed a pattern of conduct, as opposed to mere stray incidents, yet they seemingly turned a blind eye toward [the supervisor’s] harassment”).

268 See Faragher , 524 U.S. at 809 (“While proof that an employer had promulgated an antiharassment policy with complaint procedure is not necessary in every instance as a matter of law, the need for a stated policy suitable to the employment circumstances may appropriately be addressed in any case when litigating the first element of the defense.”); Holly D. v. Cal. Inst. of Tech. , 339 F.3d 1158, 1177 (9th Cir. 2003) (“The legal standard for evaluating an employer’s efforts to prevent and correct harassment, however, is not whether any additional steps or measures would have been reasonable if employed, but whether the employer’s actions as a whole established a reasonable mechanism for prevention and correction.”); see also EEOC, Promising Practices for Preventing Harassment (2017), https://www.eeoc.gov/laws/guidance/promising-practices-preventing-harassment ; EEOC, Promising Practices for Preventing Harassment in the Federal Sector , https://www.eeoc.gov/federal-sector/reports/promising-practices-preventing-harassment-federal-sector (last visited Apr. 12, 2024).

269 For further guidance on what constitutes reasonable care to prevent harassment, refer to sectionIV.C.3.a, infra . An employer also may reduce the likelihood of unlawful harassment by conducting climate surveys of employees to determine whether employees believe that harassment exists in the workplace and is tolerated, and by repeating the surveys to ensure that changes to address potential harassment have been implemented. Chai R. Feldblum & Victoria A. Lipnic, EEOC, Select Task Force on the Study of Harassment in the Workplace, Report of Co-Chairs Chai R. Feldblum & Victoria A. Lipnic (2016), https://www.eeoc.gov/sites/default/files/migrated_files/eeoc/task_force/harassment/report.pdf (discussing steps an organization may take to convey a sense of urgency about preventing harassment).

270 See, e.g. , Agusty-Reyes v. Dep’t of Educ. , 601 F.3d 45, 55 (1st Cir. 2010) (holding that a reasonable jury could conclude that the failure to disseminate the harassment policy and complaint procedure precluded the employer from establishing the first prong of the defense); Ortiz v. Sch. Bd. , 780 F. App’x 780, 786 (11th Cir. 2019) (per curiam) (denying summary judgment to the employer on the Faragher-Ellerth affirmative defense where there was evidence that the employer had failed to take reasonable steps to disseminate its anti-harassment policy).

271 See EEOC v. V & J Foods, Inc. , 507 F.3d 575, 578 (7th Cir. 2007) (explaining that, although an employer need not tailor its complaint procedure to the competence of each employee, “the known vulnerability of a protected class has legal significance”). In V & J Foods , the victims of harassment were teenage girls working part-time, and often as their first job, in a small retail outlet. Id. The court criticized the defendant’s complaint procedures as “likely to confuse even adult employees,” and stated, “[k]nowing that it has many teenage employees, the company was obligated to suit its procedures to the understanding of the average teenager.” Id.

272 EEOC v. Spud Seller, Inc. , 899 F. Supp. 2d 1081, 1095 (D. Colo. 2012) (determining a trial was required on the issue of whether the employer, which employed some individuals who spoke only Spanish, could satisfy the Faragher-Ellerth affirmative defense where the employer’s handbook contained an anti-harassment policy in English, but there was no evidence that its provisions were translated into Spanish or that written translations were supplied to Spanish-speaking employees).

273 See Clark v. United Parcel Serv., Inc. , 400 F.3d 341, 349 (6th Cir. 2005) (“While there is no exact formula for what constitutes a ‘reasonable’ sexual harassment policy, an effective policy should at least . . . require supervisors to report incidents of sexual harassment.”); Ocheltree v. Scollon Prods., Inc. , 335 F.3d 325, 334 (4th Cir. 2003) (criticizing employer’s putative sexual harassment policy where the policy, inter alia , failed to place any duty on supervisors to report incidents of sexual harassment to their superiors); Wilson v. Tulsa Junior Coll. , 164 F.3d 534, 541 (10th Cir. 1998) (criticizing employer policy for failing to “provide instruction on the responsibilities, if any, of a supervisor who learns of an incident of harassment through informal means”); Varner v. Nat’l Super Mkts. , 94 F.3d 1209, 1214 (8th Cir. 1996) (holding employer liable where the company’s policy “in effect required [the plaintiff’s] supervisor to remain silent notwithstanding his knowledge of the incidents”); cf. Ridley v. Costco Wholesale Corp. , 217 F. App’x 130, 138 (3d Cir. 2007) (declining to impose punitive damages where defendant provided new supervisors with detailed materials regarding supervisors’ obligation to address discrimination issues).

274 See, e.g. , Faragher v. City of Boca Raton , 524 U.S. 775, 808 (1998) (holding as a matter of law that the city did not exercise reasonable care to prevent the supervisors’ harassment where, among other defects, the city’s policy “did not include any assurance that the harassing supervisors could be bypassed in registering complaints”); Meritor Sav. Bank, FSB v. Vinson , 477 U.S. 57, 73 (1986) (stating that it was “not altogether surprising” that the complainant did not follow a grievance procedure that apparently required her to complain first to her supervisor, who was the alleged harasser); Sanford v. Main St. Baptist Church Manor, Inc. , 327 F. App’x 587, 596 (6th Cir. 2009) (reversing grant of summary judgment on a hostile work environment claim where the employer’s policy failed to provide a mechanism for bypassing a harassing supervisor when making a complaint, inter alia ); Clark , 400 F.3d at 349-50 (stating that a reasonable sexual harassment procedure should provide a mechanism for bypassing a harassing supervisor when making a complaint); Stewart v. Trans-Acc, Inc. , No. 1:09-cv-607, 2011 WL 1560623, at *11 (S.D. Ohio Apr. 25, 2011) (noting the employer’s policy “[c]rucially . . . does not contain a reporting procedure, much less a mechanism for bypassing a harassing supervisor”); see also Chai R. Feldblum & Victoria A. Lipnic, EEOC, Select Task Force on the Study of Harassment in the Workplace, Report of Co-Chairs Chai R. Feldblum & Victoria A. Lipnic (2016), https://www.eeoc.gov/sites/default/files/migrated_files/eeoc/task_force/harassment/report.pdf (“Employers should offer reporting procedures that are multi-faceted, offering a range of methods, multiple points-of-contact, and geographic and organizational diversity where possible, for an employee to report harassment.”).

275 See Wilson , 164 F.3d at 541 (noting deficiencies with the employer’s policy, including a supervisor-bypass option that “is located in a separate facility and is not accessible during the evening or weekend hours when many employees and students are on the various campuses”); Lamarr–Arruz v. CVS Pharm., Inc. , 271 F. Supp. 3d 646, 661 (S.D.N.Y. 2017) (the employee’s testimony that complaints to the ethics hotline were ignored raises questions regarding the reasonableness of the employer’s purported available corrective measures); Spud Seller , 899 F. Supp. 2d at 1095 (questioning whether the employer’s anti-harassment policy was sufficient where employees who spoke only Spanish could not bring complaints directly to the individuals identified in the policy because the points of contact did not speak Spanish); Wilborn v. S. Union State Cmty. Coll. , 720 F. Supp. 2d 1274, 1300 (M.D. Ala. 2010) (criticizing the employer’s complaint reporting procedure where employees were directed to file complaints with one person at an address located in a different city, the point of contact never visited the location where the harassed employee worked, and the harassed employee was not provided with any other contact information for the point of contact); Escalante v. IBP, Inc. , 199 F. Supp. 2d 1093, 1103 (D. Kan. 2002) (determining the employer failed to show it exercised reasonable care by promulgating and implementing an anti-harassment policy where it “has a confusing number of contradicting policies, each stating a different reporting mechanism, the specific policy dealing with discrimination claims only provides the employee one person to report such claims to[, and] [t]his person is located in another state, is only accessible by telephone, and the policy does not state the hours or days in which this person may be reached”); Dinkins v. Charoen Pokphand USA, Inc. , 133 F. Supp. 2d 1254, 1269 n.22 (M.D. Ala. 2001) (noting “mid-level supervisors may have blocked Plaintiffs’ attempts to contact higher-ranking supervisors” thereby rendering the complaint process inaccessible and deficient); cf. Ocheltree , 335 F.3d at 334 (finding the employer’s “open door” reporting policy deficient where the two points of contact were either always unavailable or refused to speak with the employee when the employee attempted to complain); Madray v. Publix Supermarkets, Inc ., 208 F.3d 1290, 1298 (11th Cir. 2000) (noting the employer’s policy designated several additional company representatives to whom an employee could complain regarding harassment and that these individuals were accessible to employees). Accessibility of points of contact can also be relevant when addressing the second prong of the Faragher-Ellerth affirmative defense, which considers whether the complainant unreasonably failed to take advantage of any preventive or corrective opportunities provided by the employer or to otherwise avoid harm. See infra sectionIV.C.2.b.ii and note 297.

276 See EEOC v. Mgmt. Hospitality of Racine, Inc. , 666 F.3d 422, 436 (7th Cir. 2012) (stating “an employer’s complaint mechanism must provide a clear path for reporting harassment” and criticizing the defendant for, inter alia , failing to provide any point of contact or contact information for employees to make harassment complaints); cf. Helm v. Kansas , 656 F.3d 1277, 1288 (10th Cir. 2011) (finding the employer’s policy, which included “a complaint procedure and list of personnel to whom harassment may be reported” reasonable).

277 See Cerros v. Steel Techs., Inc. , 398 F.3d 944, 954 (7th Cir. 2005) (describing a prompt investigation as a “hallmark of reasonable corrective action”).

278 See Thomas v. BET Soundstage Rest. , 104 F. Supp. 2d 558, 565-66 (D. Md. 2000) (stating that the failure to provide confidentiality or protection from retaliation where there is evidence of prevalent hostility can support a finding that the policy was defective and dysfunctional); cf. AutoZone, Inc. v. EEOC , 421 F. App’x 740, 741-42 (9th Cir. 2011) (“The EEOC introduced evidence that despite AutoZone policy requiring managers to ‘thoroughly investigate each reported allegation as confidentially as possible,’ Anderson interviewed Wing about her complaint in a semi-public part of her own store.”). An employer should make clear to employees that it will protect the confidentiality of harassment allegations to the extent possible. An employer cannot guarantee complete confidentiality since it cannot conduct an effective investigation without revealing certain information to the alleged harasser and potential witnesses. However, information about the allegation of harassment should be shared only with those who need to know about it. See Chai R. Feldblum & Victoria A. Lipnic, EEOC, Select Task Force on the Study of Harassment in the Workplace, Report of Co-Chairs Chai R. Feldblum & Victoria A. Lipnic (2016), https://www.eeoc.gov/sites/default/files/migrated_files/eeoc/task_force/harassment/report.pdf . Records relating to harassment complaints should be kept confidential on the same basis.

279 See Brenneman v. Famous Dave’s of Am., Inc. , 507 F.3d 1139, 1145 (8th Cir. 2007) (holding that the employer demonstrated that it exercised reasonable care to prevent sexual harassment where the employer had and effectively deployed a facially valid anti-harassment policy, which included a non-retaliation provision and a flexible reporting procedure that listed four individuals who may be contacted in the case of harassment); Ferraro v. Kellwood Co. , 440 F.3d 96, 102-03 (2d Cir. 2006) (concluding that the employer satisfied the first element of the affirmative defense to disability-based harassment where, among other things, it had an anti-harassment policy that prohibited harassment on account of disability, promised that complaints would be handled promptly and confidentially, and contained an anti-retaliation provision); Miller v. Woodharbor Molding & Millworks, Inc. , 80 F. Supp. 2d 1026, 1029 (N.D. Iowa 2000) (stating the gravamen of an effective anti-harassment policy includes three provisions: (1) training for supervisors, (2) an express anti-retaliation provision, and (3) multiple complaint channels for reporting the harassing conduct) (collecting cases supporting inclusion of each provision), aff’d , 248 F.3d 1165 (8th Cir. 2001); see also Jaros v. LodgeNet Entm’t Corp. , 294 F.3d 960, 966 (8th Cir. 2002) (upholding a sexual harassment jury verdict for the plaintiff where she resigned instead of cooperating with her employer’s investigation because, among other things, the Human Resources Director did nothing to assure her that she would not be subjected to retaliation).

280 This is a non-exhaustive list. See, e.g. , Chai R. Feldblum & Victoria A. Lipnic, EEOC, Select Task Force on the Study of Harassment in the Workplace, Report of Co-Chairs Chai R. Feldblum & Victoria A. Lipnic 44-60 (2016), https://www.eeoc.gov/sites/default/files/migrated_files/eeoc/task_force/harassment/report.pdf ; EEOC, Promising Practices for Preventing Harassment (2017), https://www.eeoc.gov/laws/guidance/promising-practices-preventing-harassment .

281 For a detailed discussion of promising practices for anti-harassment training, see EEOC, Promising Practices for Preventing Harassment (2017), https://www.eeoc.gov/laws/guidance/promising-practices-preventing-harassment , and EEOC, Promising Practices for Preventing Harassment in the Federal Sector , https://www.eeoc.gov/federal-sector/reports/promising-practices-preventing-harassment-federal-sector (last visited Apr. 12, 2024).

282 See Ferraro v. Kellwood Co. , 440 F.3d 96, 102 (2d Cir. 2006) (“An employer may demonstrate the exercise of reasonable care, required by the first element, by showing the existence of an antiharassment policy during the period of the plaintiff's employment, although that fact alone is not always dispositive.”).

283 See, e.g. , Wallace v. Performance Contractors, Inc ., 57 F.4th 209, 223 (5th Cir. 2023) (determining the “evidence indicates that [the defendant] had a policy in theory but not one in practice” where both the plaintiff and her husband tried to contact the human resources office several times to no avail and harassment occurred in front of other employees and was never reported, despite the defendant’s policy requiring any person witnessing harassment to report it); Clark v. United Parcel Serv., Inc. , 400 F.3d 341, 349-50 (6th Cir. 2005) (“While there is no exact formula for what constitutes a ‘reasonable’ sexual harassment policy, an effective policy should at least . . . provide for training regarding the policy.”).

284 See Brown v. Perry , 184 F.3d 388, 396 (4th Cir. 1999) (“But where, as here, there is no evidence that an employer adopted or administered an anti-harassment policy in bad faith or that the policy was otherwise defective or dysfunctional, the existence of such a policy militates strongly in favor of a conclusion that the employer ‘exercised reasonable care to prevent’ and promptly correct sexual harassment.”); see also Madray v. Publix Supermarkets, Inc. , 208 F.3d 1290, 1299 (11th Cir. 2000) (“[B]ecause we find no inherent defect in the complaint procedures established by Publix’s sexual harassment policy, nor any evidence that the policy was administered in bad faith, we conclude that Publix exercised reasonable care to prevent sexual harassment.”).

285 MacCluskey v. Univ. of Conn. Health Ctr. , 707 F. App’x 44, 47-48 (2d Cir. 2017) (“Even where an employer provides a reasonable avenue for complaint, it may be liable if it knew or should have known about the harassment and failed to take appropriate action.” (citing Duch v. Jakubek , 588 F.3d 757, 762 (2d Cir. 2009))).

286 Duch , 588 F.3d at 764-66 (imputing the supervisor’s actual or constructive knowledge of the harassment to the employer).

287 Faragher v. City of Boca Raton , 524 U.S. 775, 807 (1998); Burlington Indus., Inc. v. Ellerth , 524 U.S. 742, 765 (1998).

288 See Faragher , 524 U.S. at 807 (“If the victim could have avoided harm, no liability should be found against the employer who had taken reasonable care, and if damages could reasonably have been mitigated no award against a liable employer should reward a plaintiff for what her own efforts could have avoided.”).

289 Cf. Savino v. C.P. Hall Co. , 199 F.3d 925, 935 (7th Cir. 1999) (stating that the employee’s “unreasonable foot-dragging will result in at least a partial reduction of damages, and may completely foreclose liability”).

290 Faragher , 524 U.S. at 807-08; Ellerth , 524 U.S. at 765; see also Roby v. CWI, Inc. , 579 F.3d 779, 786 (7th Cir. 2009) (second prong of affirmative defense satisfied where the plaintiff was aware that the anti-harassment policy required immediate reporting of sexual harassment, yet she failed to say anything for at least five months); Taylor v. Solis , 571 F.3d 1313, 1318 (D.C. Cir. 2009) (second prong of affirmative defense satisfied where a reasonable employee in the plaintiff’s position would have used the employer’s complaint procedure yet the plaintiff instead posted the sexual harassment policy on her office door and told her friend that she was being harassed).

291 Minarsky v. Susquehanna Cnty ., 895 F.3d 303, 314-16 (3d Cir. 2018) (concluding that a jury could find that the plaintiff’s failure to report harassment by her supervisor was not unreasonable where, among other things, her working conditions worsened after she asserted herself in the past, the supervisor warned her that she could not trust the individuals to whom she was required to report the harassment, and the employer had known of the supervisor’s prior misconduct but “merely slapped him on the wrist”); Johnson v. West , 218 F.3d 725, 732 (7th Cir. 2000) (holding that whether the plaintiff’s failure to complain was unreasonable was a factual issue where evidence showed the harasser threatened the plaintiff, verbally abused her, and threw mail in her face); Meza-Perez v. Sbarro LLC , No. 2:19-cv-00373, 2020 WL 12752817, at *8 (D. Nev. Dec. 16, 2020) (concluding a reasonable jury could find the plaintiff’s delay in reporting was not unreasonable where the harasser repeatedly threatened the plaintiff and her family members with physical harm, termination, and deportation).

292 The employee is not required to have chosen “the course that events later show to have been the best.” Restatement (Second) of Torts § 918, comment c (1979); see also Kramer v. Wasatch Cnty. Sheriff’s Off. , 743 F.3d 726, 754 (10th Cir. 2014) (noting that the employee’s response to harassment was not necessarily unreasonable even if “20/20 hindsight” suggests that she “could have avoided” some of the harm).

293 See Pinkerton v. Colo. Dep’t of Transp. , 563 F.3d 1052, 1064 (10th Cir. 2009) (stating that an employee should not necessarily be expected to complain after the first or second incident of relatively minor harassment and that an employee is not required to report “individual incidents that are revealed to be harassment only in the context of additional, later incidents, and that only in the aggregate come to constitute a pervasively hostile work environment”); Reed v. MBNA Mktg. Sys., Inc. , 333 F.3d 27, 36-37 (1st Cir. 2003) (noting that “sometimes inaction is reasonable” and concluding that the failure to report relatively minor incidents of harassment was not unreasonable).

294 See Crockett v. Mission Hosp., Inc. , 717 F.3d 348, 357-58 (4th Cir. 2013) (concluding that the second prong of the defense was established by uncontradicted evidence that the employer counseled the complainant on how to file a formal complaint, provided her with a copy of the sexual harassment policy, and repeatedly met with her in an effort to learn what had happened so it could correct the situation, but the complainant refused, for a month, to provide any details or information about the conduct that had prompted her complaint).

295 Cf. Faragher v. City of Boca Raton , 524 U.S. 775, 806-07 (1998) (stating that employers can establish a defense only if the plaintiff unreasonably failed to make use of “a proven, effective mechanism for reporting and resolving complaints of sexual harassment, available to the employee without undue risk or expense”).

296 See id. (referencing a proven, effective complaint process that was available “without undue risk or expense”).

297 See Derry v. EDM Enters., Inc. , No. 09-CV-6187, 2010 WL 3586739, at *3 (D. Or. Sept. 13, 2010) (concluding that the employee’s failure to take advantage of the employer’s corrective opportunities was not unreasonable where the only contact persons for reporting harassment were her supervisor, who was the alleged harasser, and the CEO, whose phone number was not readily available and whom the employee was discouraged from contacting without going through her supervisor); see also supra note 275.

298 Barrett v. Applied Radiant Energy Corp. , 240 F.3d 262, 268 (4th Cir. 2001) (holding that the employee’s failure to report harassment based on speculation that complaints would be ignored was not reasonable).

299 See Monteagudo v. Asociación de Empleados del Estado Libre Asociado de Puerto Rico , 554 F.3d 164, 171-72 (1st Cir. 2009) (concluding that a jury could have determined that the plaintiff’s failure to report sexual harassment by her supervisor was not unreasonable, in part, because of the evidence of a close relationship between the harasser and officials designated to accept complaints); Shields v. Fed. Express Customer Info. Servs. Inc. , 499 F. App’x. 473, 482 (6th Cir. 2012) (concluding that a reasonable jury could find that the plaintiffs did not act unreasonably in failing to report the operations manager’s sexual harassment to other managers where the harasser repeatedly told them that other managers were his friends and would not believe the plaintiffs if they complained).

300 See Leopold v. Baccarat, Inc. , 239 F.3d 243, 246 (2d Cir. 2001) (stating evidence that the employer has ignored or resisted similar complaints could be sufficient to excuse an employee’s failure to use the employer’s complaint procedure); Mancuso v. City of Atlantic City , 193 F. Supp. 2d 789, 806 (D.N.J. 2002) (concluding jury could reasonably find that the plaintiff’s failure to complain of harassment was not unreasonable where the plaintiff repeatedly witnessed the employer’s failure to respond to coworkers’ and her own complaints); Sullivan v. Hanover Foods Corp. , No. 18-803 (MN), 2020 WL 211216, at *17 (D. Del. Jan. 14, 2020) (evidence that human resources and management frequently ignored complaints regarding race discrimination raised a genuine issue of material fact as to whether the plaintiff was unreasonable in failing to take advantage of preventive or corrective opportunities provided by the defendant); Baker v. Int’l Longshoremen’s Ass’n, Local 1423 , No. CV205-162, 2009 WL 368650 at *8 (S.D. Ga. Feb. 13, 2009) (holding that the plaintiff could introduce evidence of ignored harassment complaints to show that her failure to use the union grievance process was reasonable); see also Minarsky v. Susquehanna Cnty., 895 F.3d 303, 313 n.12 (3d Cir. 2018) (“While the policy underlying Faragher-Ellerth places the onus on the harassed employee to report her harasser, and would fault her for not calling out this conduct so as to prevent it, a jury could conclude that the employee’s non-reporting was understandable, perhaps even reasonable. That is, there may be a certain fallacy that underlies the notion that reporting sexual misconduct will end it. Victims do not always view it this way.”).

301 Barrett , 240 F.3d at 267 (holding that employee’s failure to report harassment based on a speculative fear of retaliation was not reasonable).

302 See Wyatt v. Nissan N. Am., Inc. , 999 F.3d 400, 416 (6th Cir. 2021) (denying summary judgment and concluding the plaintiff’s proffered evidence demonstrated she “was under a credible threat of retaliation” that alleviated her duty to report the harassment); Minarsky , 895 F.3d at 314 (“If a plaintiff’s genuinely held, subjective belief of potential retaliation from reporting her harassment appears to be well-founded, and a jury could find that this belief is objectively reasonable, the trial court should not find that the defendant has proven the second Faragher-Ellerth element as a matter of law.”); EEOC v. U.S. Bell, Link Techs., Corp. , No. 2:03-CV-237, 2005 WL 1683979, at *19 (N.D. Ind. July 19, 2005) (determining that female employees were not unreasonable when they failed to report harassment as a result of the harasser’s threats of retaliation and intimidation).

303 See Reed v. MBNA Mktg. Sys., Inc. , 333 F.3d 27, 37 (1st Cir. 2003) (concluding that a jury could find that the seventeen-year-old complainant did not act unreasonably in failing to report a sexual assault where her supervisor threatened to have her fired if she complained and he boasted that his father was “really good friends” with the owner); Mota v. Univ. of Tex. Hous. Health Sci. Ctr. , 261 F.3d 512, 525-26 (5th Cir. 2001) (concluding that, in light of the supervisor’s repeated threats of retaliation, a jury could infer that the employee’s nine-month delay in filing a complaint was not unreasonable); O’Brien v. Middle E. Forum , No. 2:19-cv-06078, 2021 WL 2186434, at *9 (E.D. Pa. May 28, 2021) (concluding that a reasonable jury could find that the employee’s fear of retaliation was objectively reasonable based on evidence that the harasser “frequently threatened female employees by telling them that he could hack their computers, view their communications, and that he had cameras throughout the office”; asked female employees to spy on one another and had his sister eavesdrop on them; and had told other female employees he would have them fired for being a “walking lawsuit”); Kanish v. Crawford Area Transp. Auth. , No. 1:19-cv-00338 (Erie), 2021 WL 1520516, at *8 (W.D. Pa. Mar. 26, 2021) (holding that there were material issues of fact regarding whether the plaintiff unreasonably failed to avail herself of preventive or corrective opportunities, where she feared being fired if she complained about her supervisor; the harasser viewed himself as “untouchable” because he was a supervisor and cop; and the human resources manager was already aware of the harassment but did not take any action, leading the plaintiff to believe that a complaint would be futile).

304 See EEOC v. Mgmt. Hosp. of Racine, Inc. , 666 F.3d 422, 437 (7th Cir. 2012) (stating that the employee may have been justified in not reporting the assistant manager’s harassment to the district manager because she had previously been treated harshly by a different harasser after reporting his conduct to the district manager); Still v. Cummins Power Sys. , No. 07-5235, 2009 WL 57021, at *13 (E.D. Pa. Jan. 8, 2009) (concluding that a trier of fact could find the plaintiff’s failure to report the supervisor’s racial harassment reasonable, given the plaintiff’s testimony that two other employees suffered retaliation after complaining about harassment by the same supervisor).

305 See, e.g. , Weger v. City of Ladue , 500 F.3d 710, 725 (8th Cir. 2007) (explaining that imposing vicarious liability on an employer is a compromise requiring more than “ordinary fear or embarrassment” to justify delay in complaining (quoting Reed , 333 F.3d at 35)).

306 See Minarsky, 895 F.3d at 316 (concluding that a reasonable jury could find that an employee’s delay in reporting sexual harassment by her supervisor was reasonable, in part, because of the psychological impact the harassment had on her); see also Brianna Messina, Redefining Reasonableness: Supervisory Harassment Claims in the Era of #MeToo , 168 U. Pa. L. Rev. 1061, 1084 and accompanying notes (2020) (citing studies analyzing psychological effects of sexual harassment).

307 See, e.g. , Agusty-Reyes v. Dep’t of Educ. , 601 F.3d 45, 56 (1st Cir. 2010) (stating that a jury could find that the employee exercised reasonable care to avoid harm by filing union complaints, at least one of which was copied to the employer); Watts v. Kroger Co. , 170 F.3d 505, 511 (5th Cir. 1999) (concluding that the employee made an effort “to avoid harm otherwise” where she filed a union grievance and did not utilize the employer’s harassment complaint process since both the employer and union procedures were corrective mechanisms designed to avoid harm).

308 Cf. EEOC v. Glob. Horizons, Inc. , 915 F.3d 631, 641-42 (9th Cir. 2019) (explaining that where a client was aware of discrimination and could have taken corrective action to stop it, the client may be liable); Mullis v. Mechanics & Farmers Bank , 994 F. Supp. 680, 686 (M.D.N.C. 1997) (holding that a temporary agency may be liable for harassment at a client’s workplace where the employee complained to the temporary agency and the temporary agency made no investigation into or attempt to remedy the situation). Depending upon the facts and specific nature of the employment relationship, the staffing firm, the client, or both may be legally responsible under the federal EEO laws for undertaking corrective action. See generally EEOC, Notice No. 515.002, Enforcement Guidance: Application of EEO Laws to Contingent Workers Placed by Temporary Employment A gencies and Other Staffing Firms (1997), https://www.eeoc.gov/laws/guidance/enforcement-guidance-application-eeo-laws-contingent-workers-placed-temporary .

309 As noted earlier in section IV.C.2.b.i, the principles discussed in this section (section IV.C.3) also apply in determining whether the employer has satisfied the first prong of the Faragher - Ellerth affirmative defense.

310 For further discussion of the general application of the negligence standard, see notes 229 to 232 and accompanying text.

311 See Vance v. Ball State Univ. , 570 U.S. 421, 424 (2013). The Supreme Court stressed in Vance that a complainant could “prevail simply by showing that the employer was negligent in permitting…harassment to occur.” Id. at 445; see also id. at 448-49 (explaining that an employee can establish employer liability for nonsupervisory harassment “by showing that his or her employer was negligent in failing to prevent harassment from taking place”).

312 See id. at 449 (stating that evidence relevant in determining whether the employer unreasonably failed to prevent harassment would include evidence that the employer did not monitor the workplace, that it failed to respond to complaints, that it failed to provide a system for registering complaints, or that it effectively discouraged complaints from being filed); see also Doe v. Oberweis Dairy , 456 F.3d 704, 716 (7th Cir. 2006) (stating that the employer is liable for coworker harassment if “it failed to have and enforce a reasonable policy for preventing harassment, or in short only if it was negligent in failing to protect the plaintiff from predatory coworkers”); Cerros v. Steel Techs., Inc. , 398 F.3d 944, 953 (7th Cir. 2005) (stating that implementation of a harassment policy training session was relevant to whether the employer exercised reasonable care to prevent harassment, but adding that “[t]he mere existence of such a policy . . . does not necessarily establish that the employer acted reasonably in remedying the harassment after it has occurred or in preventing future misconduct”); Ocheltree v. Scollon Prods., Inc. , 335 F.3d 325, 334-35 (4th Cir. 2003) (concluding that a jury could find that the employer had constructive knowledge of harassment where the employer failed to provide adequate avenues to complain about harassment); Miller v. Kenworth of Dothan, Inc. , 277 F.3d 1269, 1279-80 (11th Cir. 2002) (concluding that an anti-harassment policy was not effective where it was not aggressively or thoroughly disseminated, it was not posted in the workplace, managers were not familiar with it, it was not in the complainant’s personnel file, and the employer’s actual practice indicated a tolerance of harassment or discrimination); Hollins v. Delta Airlines , 238 F.3d 1255, 1258 (10th Cir. 2001) (stating that the employer’s adoption of a harassment policy that encouraged employees to report harassment to a supervisor or the EEO Director was relevant in evaluating employer liability for coworker harassment).

313 Vance , 570 U.S. at 445-46 (stating that the “nature and degree of authority wielded by the harasser is an important factor to be considered in determining whether the employer was negligent”).

314 Oberweis Dairy , 456 F.3d at 717.

315 See supra section IV.B.2 (addressing the definition of “supervisor”).

316 Vance , 570 U.S. at 449.

317 See Freitag v. Ayers , 468 F.3d 528, 539-40 (9th Cir. 2006) (rejecting the defendant’s argument that prisons are uniquely exempt from liability for sexual harassment under Title VII and affirming that prisons must implement and enforce policies reasonably calculated to minimize the risk of inmates harassing staff).

318 Risk factors for harassment are identified and discussed in an EEOC report published by the Select Task Force on the Study of Harassment in the Workplace. See Chai R. Feldblum & Victoria A. Lipnic, EEOC, Select Task Force on the Study of Harassment in the Workplace, Report of Co-Chairs Chai R. Feldblum & Victoria A. Lipnic , § E (2016), https://www.eeoc.gov/sites/default/files/migrated_files/eeoc/task_force/harassment/report.pdf .

319 See 29 C.F.R. §§ 1604.11(d), (e); see also, e.g. , Alvarez v. Des Moines Bolt Supply, Inc. , 626 F.3d 410, 419 (8th Cir. 2010); Beckford v. Dep’t of Corr. , 605 F.3d 951, 957-58 (11th Cir. 2010); Hawkins v. Anheuser-Busch, Inc. , 517 F.3d 321, 332 (6th Cir. 2008); Watson v. Blue Circle, Inc. , 324 F.3d 1252, 1257 (11th Cir. 2003).

320 See, e.g. , Nischan v. Stratosphere Quality, LLC , 865 F.3d 922, 931 (7th Cir. 2017) (holding that the employer could be liable if it knew or should have known of the non-supervisor’s harassing conduct yet failed to act).

321 See, e.g. , Sandoval v. Am. Bldg. Maint. Indus., Inc. , 578 F.3d 787, 802 (8th Cir. 2009) (stating that an employer has “actual notice of harassment when sufficient information either comes to the attention of someone who has the power to terminate the harassment, or it comes to someone who can reasonably be expected to report or refer a complaint to someone who can put an end to it”); see also West v. Tyson Foods, Inc. , 374 F. App’x 624, 634 (6th Cir. 2010) (determining it was reasonable for the jury to conclude that the employer had actual knowledge of harassment where the aggrieved employee reported harassment to her supervisor in compliance with the employer’s anti-harassment policy); Coates v. Sundor Brands, Inc. , 164 F.3d 1361, 1363-64 (11th Cir. 1999) (per curiam) (addressing the question of whether the employer had adequate notice of the harassment, the court stated, “[t]his inquiry is made easy by the fact that Sundor’s own promulgated sexual harassment policy” directs employees to report harassment to their line manager, personnel, or any other manager with whom the employee is comfortable and that “[w]ith this policy, Sundor itself answered the question of when it would be deemed to have notice of the harassment sufficient to obligate it or its agents to take prompt and appropriate remedial measures”); Adler v. Wal-Mart Stores, Inc. , 144 F.3d 664, 673 (10th Cir. 1998) (“Actual knowledge will be demonstrable in most cases where the plaintiff has reported harassment to management-level employees.”) .

322 See Huston v. Procter & Gamble Paper Prods. Corp. , 568 F.3d 100, 107-08 (3d Cir. 2009) (stating that an employee’s knowledge of harassment is imputed to the employer if the employee is specifically charged with addressing harassment, such as a human resources manager designated to receive complaints); Nischan , 865 F.3d at 932 (7th Cir. 2017) (concluding that because the employee handbook required any employee with supervisory or managerial responsibility to report any possible harassment he or she is aware of, the employer had notice if a low-level supervisor was aware of harassment directed at a coworker with the same low-level supervisor title); Clark v. United Parcel Serv., Inc. , 400 F.3d 341, 350-51 (6th Cir. 2005) (applying Title VII standards to hold that the employer could be liable for the failure to prevent and correct harassment where the company’s policy imposed the duty on all supervisors to report harassment, and multiple supervisors allegedly witnessed harassment but failed to report it to management); Crowley v. L.L. Bean, Inc. , 303 F.3d 387, 403 (1st Cir. 2002) (concluding that a team leader’s knowledge was imputed to the employer where it had a policy allowing employees to report sexual harassment to team leaders).

323 See Torres v. Pisano , 116 F.3d 625, 636-47 (2d Cir. 1997).

324 This example is adapted from the facts in Lambert v. Peri Formworks Systems, Inc. , 723 F.3d 863 (7th Cir. 2013).

325 See Clark , 400 F.3d at 350 (concluding that the employer had notice of harassment that was witnessed by supervisors with a duty to report it to management, where the employer’s anti-harassment policy required “ all supervisors and managers” to report such harassment to the appropriate management personnel) (emphasis in original).

326 See , e.g. , Okoli v. City of Balt. , 648 F.3d 216, 224 n.8 (4th Cir. 2011) (determining that, although the employee’s complaint did not explicitly mention sexual harassment, the employer “surely should have known” that the plaintiff’s complaints, which contained the word harassment and addressed “unethical” and “degrading and dehumanizing” conduct, likely encompassed sexual harassment).

327 See Valentine v. City of Chi. , 452 F.3d 670, 680-81 (7th Cir. 2006) (determining that a question of material fact existed as to whether the plaintiff’s complaints about unwanted touching provided the employer with sufficient notice of harassment); Burke v. Villa , No. 19-CV-2957, 2021 WL 5591711, at *9 (E.D.N.Y. Nov. 30, 2021) (concluding a rational juror could find the plaintiff’s complaint of continuous touching by an assistant manager to the point of aggravation was sufficiently clear to place the employer on notice of potential harassment).

328 This example is adapted from the facts in Duch v. Jakubek , 588 F.3d 757 (2d Cir. 2009).

329 See Erickson v. Wis. Dep’t of Corr. , 469 F.3d 600, 605-06 (7th Cir. 2006) (stating that Title VII’s “‘primary objective’ . . . is ‘not to provide redress but to avoid harm’” and that the duty to prevent unlawful harassment may require an employer to take reasonable steps to prevent harassment once informed of a reasonable probability that it will occur (quoting Faragher v. City of Boca Raton , 524 U.S. 775, 805-06 (1998))); id. at 606 (“[A]n employer who receives notice that some probability of sexual harassment exists must adequately respond to that information within a reasonable amount of time.”); see also Vance v. Ball State Univ. , 570 U.S. 421, 448-49 (2013) (stating that the employer is liable for harassment if it failed to act reasonably to prevent the harassment); cf. Burlington Indus. v. Ellerth , 524 U.S. 742, 764 (1998) (explaining that Title VII’s deterrent purpose would be served by encouraging employees to report harassment at an early stage before it is severe or pervasive). But see Alvarez v. Des Moines Bolt Supply, Inc. , 626 F.3d 410, 419 (8th Cir. 2010) (subdividing the course of harassment into separate periods: one during which it was neither severe nor pervasive and a second during which it was severe or pervasive, but at which point the court determined the employer took reasonable corrective measures).

330 Kramer v. Wasatch Cnty. Sheriff’s Off. , 743 F.3d 726, 756 (10th Cir. 2014) (quoting Hirase-Doi v. U.S. W. Commc’ns, Inc. , 61 F.3d 777, 783-84 (10th Cir. 1995)).

331 See e.g. , Jenkins v. Winter , 540 F.3d 742, 749 (8th Cir. 2008) (quoting Weger v. City of Ladue , 500 F.3d 710, 721 (8th Cir. 2007)).

332 See, e.g. , id .; Sandoval v. Am. Bldg. Maint. Indus., Inc. , 578 F.3d 787, 802 (8th Cir. 2009) (quoting Watson v. Blue Circle, Inc. , 324 F.3d 1252, 1259 (11th Cir. 2003)); Huston v. Procter & Gamble Paper Prods. Corp. , 568 F.3d 100, 105 n.4 (3d Cir. 2009) (quoting Kunin v. Sears Roebuck & Co. , 175 F.3d 289, 294 (3d Cir. 1999)); see also Ocheltree v. Scollon Prods., Inc. , 335 F.3d 325, 334 (4th Cir. 2003) (stating that the employer cannot adopt a “see no evil, hear no evil” strategy and that notice of harassment is imputed to the employer if a “‘reasonable [person], intent on complying with Title VII,’ would have known about the harassment” (quoting Spicer v. Va. Dep’t of Corr. , 66 F.3d 705, 710 (4th Cir. 1995))).

333 Chapman v. Oakland Living Ctr. , 48 F.4th 222, 232 (4th Cir. 2022) (concluding that a reasonable jury could find that the employer had constructive notice of harassment where the employer failed to produce evidence that it had a harassment reporting policy when the harassment occurred and, although the employer had an employee handbook, the only copy was kept in a desk where the plaintiff may never have seen it).

334 This example is adapted from the facts in Miller v. Kenworth of Dothan, Inc. , 277 F.3d 1269 (11th Cir. 2002).

335 Waldo v. Consumers Energy Co. , 726 F.3d 802, 814 (6th Cir. 2013) (stating that a base level of reasonable corrective action may include, among other things, prompt initiation of an investigation); Dawson v. Entek Int’l , 630 F.3d 928, 940 (9th Cir. 2011) (stating that an adequate remedy requires the employer to intervene promptly).

336 See Crawford v. BNSF Ry. Co ., 665 F.3d 978, 985 (8th Cir. 2012) (concluding that the defendant exercised reasonable care to prevent and correct harassment when it initiated an investigation upon receiving a harassment complaint, placed the alleged perpetrator on administrative leave within two days, and terminated him within two weeks); Pantoja v. Dep’t of Air Force , EEOC Appeal No. 01995176, 2001 WL 1526459, at *1 (Nov. 21, 2001) (affirming administrative judge’s decision that the agency was not liable for alleged sexual harassment where the agency immediately investigated the allegations and within one day moved the alleged harasser to another building).

337 See EEOC v. Mgmt. Hosp. of Racine, Inc. , 666 F.3d 422, 436 (7th Cir. 2012) (stating that a two-month delay in initiating an investigation was not the type of response “reasonably likely to prevent the harassment from recurring” (quoting Cerros v. Steel Techs., Inc. , 398 F.3d 944, 954 (7th Cir. 2005))).

338 See Hafford v. Seidner , 183 F.3d 506, 514 (6th Cir. 1999) (denying the employer’s motion for summary judgment where the employer failed to investigate racially abusive phone calls that were known to the employer, noting that “[e]arlier action may have discouraged the later calls and other conduct toward [the employee]”). For federal employers, EEOC Management Directive 715 (MD-715), which is the policy guidance the EEOC provides to federal agencies for their use in establishing and maintaining effective EEO programs, at Part G (Agency Self-Assessment Checklist) asks, in the context of receiving a harassment allegation, whether the agency conducted a prompt inquiry “beginning within 10 days of notification” of alleged harassment. See EEOC, MD-715 - PART G Agency Self-Assessment Checklist, at C.2.a.5, https://www.eeoc.gov/federal-sector/management-directive/md-715-part-g-agency-self-assessment-checklist (last visited Apr. 12, 2024).

339 See Rockymore v. U.S. Postal Serv. , EEOC Appeal No. 0120110311, 2012 WL 424237, at *5 (Jan. 31, 2012) (finding that the agency failed to take prompt corrective action where it did not provide any justification for its two-week delay in responding to the complainant’s sexual harassment complaint, particularly considering the complainant’s indication that the alleged harasser had touched her).

340 Baldwin v. Blue Cross/Blue Shield of Ala. , 480 F.3d 1287, 1304 (11th Cir. 2007); see also EEOC v. Boh Bros. Constr. Co. , 731 F.3d 444, 465-66 (5th Cir. 2013) (en banc) (holding that a reasonable jury could conclude that the employer failed to take reasonable measures to prevent and correct harassment where, among other things, the harassment complaint resulted in a belated and cursory 20-minute investigation in which the investigator did not take any notes or ask any questions during his meeting with the complainant, and he never contacted the employer’s EEO Officer or sought advice about how to handle the matter); Shields v. Fed. Express Customer Info. Servs. Inc. , 499 F. App’x 473, 480 (6th Cir. 2012) (concluding that a jury could find that the employer might have uncovered evidence of harassment if it had conducted a thorough investigation); Ross v. City of Dublin, No. 2:14-CV-02724, 2016 WL 7117389, at *18 (S.D. Ohio Dec. 7, 2016) (“A reasonable jury could find that [the employer’s] failure to interview [the complainant] . . . manifests indifference or unreasonableness.”); Lightbody v. Wal-Mart Stores E., L.P. , No. 13-cv-10984, 2014 WL 5313873, at *5 (D. Mass. Oct. 17, 2014) (concluding that a reasonable jury could find that the employer was liable for sexual harassment of the plaintiff because, in investigating the plaintiff’s complaint, it failed to follow leads that bore on the alleged harasser’s credibility); Grimmett v. Ala. Dep’t of Corr. , No. CV-11-BE-3594-S, 2013 WL 3242751, at *13 (N.D. Ala. June 25, 2013) (concluding that the employer failed to show that it exercised reasonable care where it presented general evidence that it had initiated an investigation but no specific evidence that would enable the court to evaluate the adequacy of the investigation and the employer’s conclusory finding that the harassment complaint was unfounded).

341 See Hathaway v. Runyon , 132 F.3d 1214, 1224 (8th Cir. 1997) (“It is not a remedy for the employer to do nothing simply because the coworker denies that the harassment occurred, and an employer may take remedial action even where a complaint is uncorroborated.” (citations omitted)).

342 This example is adapted from the facts in EEOC v. Boh Brothers Construction Company, LLC , 731 F.3d 444 (5th Cir. 2013) (en banc).

343 In the context of federal sector employment, federal agencies should consult with legal counsel to address potential Privacy Act concerns.

344 At a minimum, pursuant to EEOC regulation, employers are required to keep records for a period of one year from the date of the making of the record or the personnel action involved, whichever occurs later. If an EEOC charge is filed, the employer is required to preserve all records relevant to the charge until its final disposition. The date of final disposition is when the statutory period for filing a lawsuit expires or, where a lawsuit has been filed by an aggrieved person, the EEOC, or the Department of Justice, the date when the litigation is terminated. 29 C.F.R. § 1602.14.

345 See Swenson v. Potter , 271 F.3d 1184, 1192 (9th Cir. 2001) (stating the obligation to take prompt corrective action is comprised of two parts, of which “[t]he first part consists of the temporary steps the employer takes to deal with the situation while it determines whether the complaint is justified”).

346 See Guess v. Bethlehem Steel Corp. , 913 F.2d 463, 465 (7th Cir. 1990) (agreeing that a “remedial measure that makes the victim of sexual harassment worse off is ineffective per se” and that, thus, a transfer that reduces a complainant’s wages or impairs her prospects for promotion is not adequate corrective action); see also EEOC v. Cromer Food Servs., Inc. , 414 F. App’x 602, 608 (4th Cir. 2011) (stating that the offer to transfer the complainant to another shift that would have made him worse off was not an acceptable remedial measure); Steiner v. Showboat Operating Co. , 25 F.3d 1459, 1464 (9th Cir. 1994) (concluding that remedial action was not adequate where the employer twice changed the complainant’s schedule to separate her from the harasser, rather than changing the harasser’s shift or work area or firing the harasser); Taylor v. CSX Transp. , 418 F. Supp. 2d 1284, 1307-08 (M.D. Ala. 2006) (agreeing with the plaintiff that evidence that an employer’s remedy placed the plaintiff in a worse position than prior to complaining about harassment is evidence that the employer did not take appropriate corrective action); cf. Hostetler v. Quality Dining, Inc., 218 F.3d 798, 812 (7th Cir. 2000) (concluding that, where the employer transferred a harassed employee in response to a harassment complaint to a position that left her materially worse off, the employer could be held liable for the transfer because it “breache[d] the duty of care it owe[d] to the harassed employee”).

347 Cf. EEOC, Enforcement Guidance on Retaliation and Related Issues § II.C (2016), https://www.eeoc.gov/laws/guidance/enforcement-guidance-retaliation-and-related-issues#C._Causal ; id. at Example 31 (providing example of preliminary relief granted to prohibit retaliation against alleged harassment victims during pendency of investigation (citing EEOC v. Evans Fruit Co. , No. CV-10-3033, 2010 WL 2594960, at *1-2 (E.D. Wash. June 24, 2010))).

348 Wyninger v. New Venture Gear, Inc. , 361 F.3d 965, 976 (7th Cir. 2004) (quoting Berry v. Delta Airlines, Inc. , 260 F.3d 803, 811 (7th Cir. 2001)).

349 See, e.g. , Waldo v. Consumers Energy Co. , 726 F.3d 802, 814 (6th Cir. 2013) (stating that the employer’s response is generally adequate “if it is reasonably calculated to end the harassment” (quoting Jackson v. Quanex Corp. , 191 F.3d 647, 663 (6th Cir. 1999))); Hoyle v. Freightliner, LLC , 650 F.3d 321, 335 (4th Cir. 2011) (holding that a reasonable jury could find that the employer was liable for harassment where it failed to promptly and effectively enforce its anti-harassment policies, which called for a “firm response designed to end the harassment”); Dawson v. Entek Int’l , 630 F.3d 928, 940 (9th Cir. 2011) (explaining that the reasonableness of a remedy depends on its ability to stop the harasser from continuing his conduct and to persuade potential harassers to refrain from engaging in unlawful conduct); cf. Vance v. Ball State Univ. , 646 F.3d 461, 473 (7th Cir. 2011) (concluding that the employer was not liable where it took reasonable steps to prevent the harassment from continuing), aff’d , 570 U.S. 421 (2013).

350 See, e.g. , Campbell v. Haw. Dep’t of Educ. , 892 F.3d 1005, 1018 (9th Cir. 2018) (stating that the reasonableness of corrective action is evaluated from the perspective of what the employer knew or should have known when it took the action); McCombs v. Meijer, Inc. , 395 F.3d 346, 358 (6th Cir. 2005) (concluding that the jury was properly instructed to consider the reasonableness of the employer’s response to harassment in light of what it knew at the time that the harassment occurred); Cerros v. Steel Techs., Inc. , 398 F.3d 944, 953 (7th Cir. 2005) (stating that the reasonableness of the employer’s response turns on the facts and circumstances when harassment is alleged).

351 See, e.g. , Pryor v. United Air Lines, Inc ., 791 F.3d 488, 498 (4th Cir. 2015) (collecting cases) (“It is only in light of the nature of the harassment that we can see whether a company’s response was proportional by examining the promptness of any investigation, the specific remedial measures taken, and the effectiveness of those measures.”); Scarberry v. Exxonmobil Oil Corp., 328 F.3d 1255, 1259-60 (10th Cir. 2003) (stating that the “ test is whether the employer’s response to each incident of harassment is proportional to the incident and reasonably calculated to end the harassment and prevent future harassing behavior”). But see Tutman v. WBBM–TV, Inc./CBS, Inc. , 209 F.3d 1044, 1049 (7th Cir. 2000) (“[T]he question is not whether the punishment was proportionate to [the] offense but whether [the employer] responded with appropriate remedial action reasonably likely under the circumstances to prevent the conduct from recurring.”).

352 See Hawkins v. Anheuser-Busch, Inc. , 517 F.3d 321, 342 (6th Cir. 2008) (concluding that, although separating the harasser and complainant may be adequate in some cases, it was not sufficient in this case where the wrongdoer was a serial harasser and management repeatedly transferred the harasser’s victims instead of taking other corrective action aimed at stopping the harasser’s misconduct, such as training, warning, or monitoring the harasser).

353 See Vance , 570 U.S. at 445-46; Doe v. Oberweis Dairy , 456 F.3d 704, 717 (7th Cir. 2006). For a discussion of when vicarious liability applies, refer to section IV.B.2, supra .

354 See Vance , 570 U.S. at 445-46.

355 See, e.g. , May v. Chrysler Grp., LLC , 716 F.3d 963, 971 (7th Cir. 2012) (stating that the success or failure of corrective action in stopping harassment is not determinative as to employer liability but is nevertheless material in determining whether corrective action was reasonably likely to prevent the harassment from recurring); Wilson v. Moulison N. Corp. , 639 F.3d 1, 8 (1st Cir. 2011) (rejecting the argument that corrective action must have been inadequate because it failed to stop the harassment as “nothing more than a post hoc rationalization”); Adler v. Wal-Mart Stores, Inc. , 144 F.3d 664, 676 (10th Cir. 1998) (“Because there is no strict liability and an employer must only respond reasonably, a response may be so calculated even though the perpetrator might persist.”).

356 Smith v. Sheahan , 189 F.3d 529, 535 (7th Cir. 1999) (“Just as an employer may escape liability even if harassment recurs despite its best efforts, so it can also be liable if the harassment fortuitously stops, but a jury deems its response to have fallen below the level of due care.”); see Fuller v. City of Oakland , 47 F.3d 1522, 1529 (9th Cir. 1995) (stating that an employer that fails to take any corrective action is liable for ratifying unlawful harassment even if the harasser voluntarily stops); Engel v. Rapid City Sch. Dist. , 506 F.3d 1118, 1123-24 (8th Cir. 2007) (stating that an employer that fails to take proper remedial action in response to harassment is liable because the “combined knowledge and inaction may be seen as demonstrable negligence, or as the employer’s adoption of the offending conduct and its results, quite as if they had been authorized affirmatively as the employer’s policy” (quoting Faragher v. City of Boca Raton , 524 U.S. 775, 789 (1998))).

357 See discussion of prompt and adequate investigation at section IV.C.3.b.ii(a).

358 See cases cited in note 346.

359 See Carter v. Chrysler Corp. , 173 F.3d 693, 702 (8th Cir. 1999) (enumerating factors to be assessed in evaluating the reasonableness of remedial measures and listing potential corrective actions).

360 Dunn v. Washington Cnty. Hosp. , 429 F.3d 689, 691 (7th Cir. 2005).

361 See Swenson v. Potter , 271 F.3d 1184, 1196 (9th Cir. 2001) (“As a matter of policy, it makes no sense to tell employers that they act at their legal peril if they fail to impose discipline even if they do not find what they consider to be sufficient evidence of harassment. . . . Employees are no better served by a wrongful determination that harassment occurred than by a wrongful determination that no harassment occurred.”).

362 Shields v. Fed. Express Customer Info. Servs. Inc. , 499 F. App’x 473, 479-80 (6th Cir. 2012) (explaining that, even if the employer’s investigation did not substantiate sexual harassment claim, the employer still had the responsibility to ensure that the accused harasser did not engage in harassment in the future, such as by monitoring the accused harasser’s conduct); cf. Christian v. AHS Tulsa Reg’l Med. Ctr., LLC , 430 F. App’x 694, 698-99 (10th Cir. 2011) (affirming lower court conclusion that the employer took reasonable corrective action where, despite a “reasonably thorough investigation,” its findings were inconclusive but it nevertheless counseled the alleged harasser as to its antidiscrimination policy, and he remained subject to more serious sanctions if he was again accused of misconduct).

363 In some cases, the application of the EEO statutes enforced by the EEOC may implicate other rights or requirements including those under the United States Constitution; other federal laws, such as the Religious Freedom Restoration Act (RFRA); or sections 702(a) and 703(e)(2) of Title VII. Whether enforcement of federal workplace anti-harassment laws implicates other legal requirements, and if so, the interplay between federal workplace antidiscrimination laws and any such other legal doctrine, is beyond the scope of this document. For further information, see the relevant sections of EEOC’s Compliance Manual Section on Religious Discrimination. EEOC, Compliance Manual Section 12: Religious Discrimination , No. 915.063, §§ 12-I.C, 12-III.D, and Addendum (2021), https://www.eeoc.gov/laws/guidance/section-12-religious-discrimination and EEOC, Compliance Manual Section 2: Threshold Issue s, No. 915.003, § 2-III.B.4.b.I (2000), https://www.eeoc.gov/laws/guidance/section-2-threshold-issues . As with all investigations, charges raising any of these arguments must be considered as presented on a case-by-case basis.

364 Under Title VII, “undue hardship is shown when a burden is substantial in the overall context of an employer’s business,” “tak[ing] into account all relevant factors in the case at hand, including the particular accommodations at issue and their practical impact in light of the nature, size and operating cost of an employer.” Groff v. DeJoy , 600 U.S. 447, 468, 470-71 (2023). With respect to relevant EEOC guidance on religious accommodation, the Court noted that “[w]e have no reservations in saying that a good deal of the EEOC’s guidance in this area is sensible and will, in all likelihood, be unaffected by our clarifying decision today.” Id. at 472. EEOC’s Compliance Manual Section on Religious Discrimination, a guidance document that was issued prior to the Groff opinion, explains that “[c]osts to be considered include not only direct monetary costs but also the burden on the conduct of the employer’s business,” which in appropriate circumstances can include adverse effects on employee morale and other impacts on coworkers, customers, and workplace productivity. EEOC, Compliance Manual Section 12: Religious Discrimination , No. 915.063, §§ 12-III.D, 12-IV.B.2 (2021), https://www.eeoc.gov/laws/guidance/section-12-religious-discrimination#h_67399831738041610749896553 . The guidance also explains: “Religious expression can create undue hardship if it disrupts the work of other employees or constitutes — or threatens to constitute — unlawful harassment. Conduct that is disruptive can still constitute an undue hardship, even if it does not rise to the level of unlawful harassment.” Id. § 12-IV.C.6.a, https://www.eeoc.gov/laws/guidance/section-12-religious-discrimination#h_48176006345391610750058898 . For more information on balancing religious expression with anti-harassment measures, refer to EEOC Compliance Manual Section 12: Religious Discrimination , No. 915.063, at sections 12-IV.C.6.a. and 12-IV.D. (2021), https://www.eeoc.gov/laws/guidance/section-12-religious-discrimination#h_48176006345391610750058898 .

365 See Peterson v. Hewlett-Packard Co. , 358 F.3d 599, 607 (9th Cir. 2004). Accommodating an employee’s religious belief will not impose undue hardship “merely because the employee’s co-workers find [the] conduct irritating or unwelcome.” Id. ; see also Groff , 600 U.S. at 472 (“[A] coworker’s dislike of ‘religious practice and expression in the workplace’ or ‘the mere fact [of] an accommodation’ is not ‘cognizable to factor into the undue hardship inquiry.’”) (citing TWA v. Hardison , 432 U.S. 63, 89-90 (1977)); Brown v. Polk Cnty. , 61 F.3d 650, 656-57 (8th Cir. 1995) (determining that the employer could be liable for failing to accommodate a department director’s “spontaneous” and “entirely voluntary” prayers that “did not occur regularly” and “occasional affirmations of Christianity” with subordinates where the employer offered only speculative concerns about “eventual polarization between born-again Christian employees and other employees” and perceptions of favoritism). While an employer must accept some degree of coworker discomfort when providing an accommodation for religious expression under Title VII, “it need not accept the burdens that would result from allowing actions that demean or degrade, or are designed to demean or degrade, members of its workforce.” Peterson , 358 F.3d at 607-08.

366 See, e.g. , Powell v. Yellow Book USA, Inc. , 445 F.3d 1074, 1078 (8th Cir. 2006) (concluding that the employer was not liable for religious harassment of the plaintiff because it took prompt and appropriate remedial action after learning of the plaintiff’s objections to her coworker’s proselytizing); see also Ervington v. LTD Commodities, LLC , 555 F. App’x 615, 617-18 (7th Cir. 2014) (concluding that the employer was not required to accommodate an employee by allowing her to distribute pamphlets that were offensive to coworkers, including material that negatively depicted Muslims and Catholics and stated that they would go to hell); Chalmers v. Tulon Co. , 101 F.3d 1012, 1021 (4th Cir. 1996) (holding that the employer did not have to accommodate an employee who sent proselytizing letters to coworkers invading their privacy and criticizing their personal lives because doing so could subject the employer to possible religious harassment lawsuits).

367 Sassaman v. Gamache , 566 F.3d 307, 311-12 (2d Cir. 2009) (concluding that a male supervisor established a prima facie case of sex discrimination when he presented evidence showing that he was terminated after being accused of sexual harassment by a female employee and was told by his supervisor that “you probably did what she said you did because you’re male and nobody would believe you anyway”).

368 As to federal employers, the EEOC’s Promising Practices for Preventing Harassment in the Federal Sector recommends that agencies promptly, thoroughly, and impartially investigate alleged harassment and take immediate and appropriate corrective action even if the complainant or alleged victim does not want the agency to investigate or correct the alleged harassment. EEOC, Promising Practices for Preventing Harassment in the Federal Sector , at Part B n.28, https://www.eeoc.gov/federal-sector/reports/promising-practices-preventing-harassment-federal-sector#_ftn28

369 Some courts have suggested that it may be lawful to honor such a request in some circumstances, but that it may be necessary to take corrective action, despite a complainant’s wishes, if harassment is severe. See Hardage v. CBS Broad. Inc. , 427 F.3d 1177, 1186 (9th Cir. 2005) (concluding that the employer acted reasonably in not investigating a complaint where the complainant said he wanted to handle the situation himself and failed to indicate the severity of the harassment, though the employer might have a duty to take corrective action in other circumstances, despite a complainant’s wishes), amended by 433 F.3d 672 (9th Cir. 2006), amended by 436 F.3d 1050 (9th Cir. 2006); Torres v. Pisano , 116 F.3d 625, 639 (2d Cir. 1997) (concluding that, although there is a point at which “harassment becomes so severe that a reasonable employer simply cannot stand by, even if requested to do so by a terrified employee,” the employer acted reasonably here in honoring an employee’s request to keep the matter confidential and not take action until a later date, where the employee had recounted only a few relatively minor incidents of harassment).

370 See Torres , 116 F.3d at 639 (stating that the employer most likely could not honor a single employee’s request not to take action if other workers were also being harassed).

371 Employers may hesitate to set up such a mechanism due to concern that it may create a duty to investigate anonymous complaints, even if based on mere rumor. To avoid any confusion as to whether a complaint through such a phone line or website triggers an investigation, the employer should make it clear that the person who receives the inquiry is not a management official and can only answer questions and provide information. An investigation will proceed only if a complaint is made through the internal complaint process or if management otherwise learns about potential harassment.

372 For a discussion of how to determine whether an individual is an employee of the employment agency, the client, or both, refer to EEOC, Notice No. 915.002, Enforcement Guidance: Application of EEO Laws to Contingent Workers Placed by Temporary Employment A gencies and Other Staffing Firms (1997), 1997 WL 33159161, at *5-6, https://www.eeoc.gov/laws/guidance/enforcement-guidance-application-eeo-laws-contingent-workers-placed-temporary .

373 See, e.g. , EEOC v. Glob. Horizons , Inc. , 915 F.3d 631, 642 (9th Cir. 2019) (stating that a defendant employer may be liable for a joint employer’s conduct but only if the defendant knew or should have known about the other employer’s conduct and “failed to undertake prompt corrective measures within its control” (quoting EEOC, Notice No. 915.002, Enforcement Guidance: Application of EEO Laws to Contingent Workers Placed by Temporary Employment Agencies and Other Staffing Firms (1997), 1997 WL 33159161, at *11, https://www.eeoc.gov/laws/guidance/enforcement-guidance-application-eeo-laws-contingent-workers-placed-temporary )); Butler v. Drive Auto. Indus. of Am., Inc. , 793 F.3d 404, 414-16 (4th Cir. 2015) (holding that the defendant, an auto parts manufacturer, exercised sufficient control over a temporary worker to be considered her joint employer and therefore the defendant could be held liable for sexual harassment and retaliation experienced by the plaintiff while working at the defendant’s facility).

374 Glob. Horizons , 915 F.3d at 641-42 (explaining that where a client was aware of discrimination and could have taken corrective action to stop it, the client may be liable).

375 See id. (holding that two joint employers could be held liable for the same hostile environment if both knew or should have known of it and both had the ability to take corrective action); Magnuson v. Peak Tech. Servs. , 808 F. Supp. 500, 511-14 (E.D. Va. 1992) (where the plaintiff was subjected to sexual harassment by her supervisor during a job assignment, three entities could be found liable: the staffing firm that paid her salary and benefits, the automobile company that contracted for her services, and the retail car dealership to which she was assigned; the staffing firm and automobile company were held to the standard for harassment by non-employees, under which an entity is liable if it had actual or constructive knowledge of the harassment and failed to take immediate and appropriate corrective action within its control); cf. Burton v. Freescale Semiconductor, Inc. , 798 F.3d 222, 229 (5th Cir. 2015) (“A staffing agency is liable for the discriminatory conduct of its joint-employer client if it participates in the discrimination, or if it knows or should have known of the client’s discrimination but fails to take corrective measures within its control.”) (ADA discriminatory termination case); Whitaker v. Milwaukee Cnty. , 772 F.3d 802, 811-12 (7th Cir. 2014) (“The firm also is liable if it knew or should have known about the client’s discrimination and failed to undertake prompt corrective measures within its control .” (quoting EEOC, Notice No. 915.002, Enforcement Guidance: Application of EEO Laws to Contingent Workers Placed by Temporary Employment A gencies and Other Staffing Firms (1997))) (emphasis in original).

376 See Mullis v. Mechs. & Farmers Bank , 994 F. Supp. 680, 686 (M.D.N.C. 1997) (holding a temporary agency may be liable for harassment at a client’s workplace where the employee complained to the temporary agency and the temporary agency made no investigation into or attempt to remedy the situation).

377 As discussed supra at section IV.C.3.b.ii(a) and section IV.C.3.b.ii(b), reassigning an employee who complains about harassment will generally not be an appropriate remedial measure and could possibly constitute retaliation. However, reassignment may be the only feasible option in circumstances where a temporary agency lacks control over the alleged harasser or workplace.

378 See, e.g. , Ellis v. Houston , 742 F.3d 307, 318, 320-22 (8th Cir. 2014) (observing that harassment of Black correctional officers working on the same shift was directed at them as a group and that each of the officers became aware of any harassment experienced by the others).

379 EEOC v. Hill Country Farms, Inc. , No. 3:11-cv-00041 (S.D. Iowa May 1, 2013), ECF No. 92; Press Release, EEOC, Jury Awards $240 Million for Long-Term Abuse of Workers with Intellectual Disabilities (May 1, 2013), https://www.eeoc.gov/newsroom/jury-awards-240-million-long-term-abuse-workers-intellectual-disabilities ; see also Dan Barry, The ‘Boys’ in the Bunkhouse , N.Y. Times, Mar. 9, 2014, https://www.nytimes.com/interactive/2014/03/09/us/the-boys-in-the-bunkhouse.html .

380 This example is adapted from the facts in Ellis v. Houston , 742 F.3d 307 (8th Cir. 2014).

381 Int’l Bhd. of Teamsters v. United States , 431 U.S. 324, 336 (1977) (stating that a pattern-or-practice claim required the government to establish that “racial discrimination was the company’s standard operating procedure[,] the regular rather than the unusual practice”); see also EEOC v. Pitre Inc. , 908 F. Supp. 2d 1165, 1178-79 (D.N.M. 2012) (denying the defendant’s motion to dismiss and permitting EEOC to proceed to jury trial under pattern-or-practice method of proof); EEOC v. Mitsubishi Motor Mfg. of Am., Inc. , 990 F. Supp. 1059, 1069-70 (C.D. Ill. 1998) (concluding that a pattern or practice of sexual harassment could be established by evidence that the employer regularly tolerated unlawful sexual harassment at its auto assembly plant); Jenson v. Eveleth Taconite Co. , 824 F. Supp. 847, 888 (D. Minn. 1993) (concluding that the employer’s tolerance of a sexually hostile environment at a mine and processing plant made sexual harassment of women the “standard operating procedure”).

382 Mitsubishi , 990 F. Supp. at 1074; see also EEOC v. Dial Corp. , 156 F. Supp. 2d 926, 946-47 (N.D. Ill. 2001) (stating that pattern-or-practice liability turns not on the particularized experiences of individual claimants but on the landscape of the total work environment).

383 EEOC v. Int’l Profit Assocs., Inc. , No. 01 C 4427, 2007 WL 3120069, at *17 (N.D. Ill. Oct. 23, 2007) (holding that the EEOC was required to establish that sexual harassment that occurred at the worksite during the relevant time period, taken as a whole, was sufficiently severe or pervasive that a reasonable woman would have found the work environment hostile or abusive).

384 EEOC v. Glob. Horizons, Inc. , 7 F. Supp. 3d 1053, 1058-63 (D. Haw. 2014).

385 See generally Mitsubishi , 990 F. Supp. at 1075.

After an employer’s responsibility to take overarching action has been established, employees’ entitlement to individual relief is determined on a case-by-case basis. Id. at 1077.

386 This example is adapted from the facts in EEOC v. Dial Corp. , 156 F. Supp. 2d 926 (N.D. Ill. 2001).

387 Proposed Enforcement Guidance on Harassment in the Workplace, 88 Fed. Reg. 67,750 (Oct. 2, 2023),  https://www.federalregister.gov/d/2023-21644 .  The proposed guidance also was posted prominently on the EEOC’s website at www.eeoc.gov.

Statement from Toronto’s Medical Officer of Health: Decriminalization of drugs for personal use

As Toronto’s Medical Officer of Health, I want to address the recent developments in British Columbia regarding their proposed modification to their federal exemption for the simple possession of small amounts of drugs for personal use. The aim, as I understand it, is to equip law enforcement with additional measures to address public drug use. There has been criticism of Toronto’s decriminalization efforts, suggesting we focus on treatment rather than decriminalization. Decriminalization is fundamentally recognizing that addiction is a health issue – and therefore requires health-based interventions. Decriminalization is not legalization.

Toronto, like many other areas, grapples with the intertwined challenges of untreated addiction, mental illnesses and homelessness – a triple crisis demanding solutions from the whole of society and all levels of government. Drug addiction is a health issue, not a criminal issue. Our city urgently needs more publicly funded treatment options and accessible mental health supports, as well as affordable housing, all of which are severely lacking.

We have never seen this toxic a drug supply, this level of homelessness and this level of mental health crises in our history and like other Toronto residents, I see this on our streets and in our communities every single day. And we know we cannot arrest our way out of this crisis. On open public drug use, let me be clear: lighting up a crack pipe on a playground or injecting drugs on the subway is not acceptable and should not be allowed. Selling or trafficking drugs is illegal. But arresting individuals who are carrying drugs for their own personal use isn’t effective.

Reducing the harms associated with drug use and ensuring ALL pathways to a range of treatment options are available is paramount and, as outlined in our five-year plan – Our Health, Our City – requires the collaboration and commitment of many partners.

Our application for an exemption to the federal law that criminalizes the possession of drugs for personal use was developed in collaboration with a wide range of stakeholders, including individuals with lived experience who use drugs, organizations who serve them and the Toronto Police Service.

The model is evidence-informed and aims to reduce harms associated with drug use, promote and provide pathways to treatment and does not sacrifice public safety. This is only ONE tool that is necessary to address the crises we are currently facing.

As Toronto’s Medical Officer of Health, my role is to bring forward and implement population health interventions that improve health – and reduce harms harm – for every Toronto resident, no matter the issue. Our goal is to cultivate a city where everyone can thrive. To achieve this, we remain committed to partnering with community groups, governmental agencies and stakeholders at all levels to implement effective, sustainable solutions.

Dr. Eileen de Villa Toronto Medical Officer of Health

Dr. Eileen de Villa, Toronto’s Medical Officer of Health, addresses the decriminalization of drugs for personal use in a video .