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Kimberly Bailey’s fascinating article, Male Same-Sex “Horseplay”: The Epicenter of Sexual Harassment? seeks to expose and to further analyze harassment of women by paying attention to the patterns and meaning of male-male harassment between straight men. By the sophisticated use of masculinities theory and research, she seeks to expand not only the boundaries of male-male harassment but also the linkages between male-male and male-female harassment. Sexual
harassment doctrine as constructed thus far excludes certain conduct as not discriminatory. As Professor Bailey notes, in Oncale v. Sundowner Offshore Services, Inc., the Court stated that it was not creating a “general civility code.” Professor Bailey seeks to carve out some male on male “horseplay” as discrimination that should be actionable under sexual harassment theory rather than tolerated or understood as nondiscriminatory. More broadly, Professor Bailey suggests male on male harassment is central to all sexual harassment.