Our federal court recently ruled that a food packaging company cannot be held liable for the alleged years of sexual harassment by a co-worker when there was no evidence the employer had knowledge or a chance to investigate. Once the employee reported the sexual harassment, the employer immediately began its investigation and offered to change her work assignment during the investigation. But the employee resigned the day following her complaint, and therefore the employer was unable to resolve her complaint or take action. Cooper v. Smithfield Packing Co. Inc. in the U.S. Court of Appeals for the Fourth Circuit.