In the recent Supreme Court ruling in Burlington Industries vs.Ellerth,the court held:

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The correct choice is D because in the Supreme Court ruling in Burlington Industries vs. Ellerth, the court held that employers are automatically liable if supervisors take tangible employment action toward the person they are harassing. This means that if a supervisor takes an action such as demotion, termination, or reduction of pay as a result of harassment, the employer will be held liable without the need for the complainant to prove intent to harass on the part of the harasser. This ruling has become known as the "tangible employment action" standard.

In the Recent Supreme Court Ruling in Burlington Industries Vs