Huston v. Procter & Gamble Paper Products, 2009 WL 1587649 (3d Cir., June 8, 2009) – The Third Circuit Court of Appeals recently took the opportunity to clarify the previously undeveloped concept of what constitutes a “management level” employee for purposes of imputing knowledge of sexual harassment to the employer under Title VII. Employing agency principles, the court stated knowledge is imputed to the employer only when that knowledge is material to the duties performed for the employer, either 1) because the employee is sufficiently senior in the governing hierarchy, or otherwise in a position of administrative responsibility over other employees, that such knowledge is important to his or her general managerial duties; or 2) when the employee is specifically employed to deal with sexual harassment.