10.2190/UVFQ-A18N-PWWL-4RCG UVFQA18NPWWL4RCG 39 The Americans with Disabilities Act and the Hostile Work Environment 39 53 20020509 20020509 20020509 20020509 UVFQA18NPWWL4RCG.pdf http://baywood.metapress.com/link.asp?target=contribution&id=UVFQA18NPWWL4RCG 1 Mary Beth Hamilton To date the appellate courts have not explicitly recognized the hostile work environment as a cause of action under the Americans with Disabilities Act. They have not done so even though the language in Title VII that created the hostile work environment is identical to language found in the Americans with Disabilities Act. This article reviews the hostile work environment under Title VII and proposes the elements for a hostile work environment under the Americans with Disabilities Act.