In what ways do the standards used to attribute liability for harassment to employers differ depending on whether the harassers are managers or coworkers? Is it appreciably easier for plaintiffs to establish liability under the affirmative defense? $[$See David J$.$ Walsh. $$Small Change: An Empirical Analysis of the Effect of Supreme Court Precedents on Federal Appeals Court Decisions in Sexual Harassment Cases, $19932005.$ Berkeley Journal of Employment and Labor Law $30,$ no$.2(2009)$: $461525.]$