Under the unified approach, in certain circumstances, the proven hostile-environment sexual harassment by the plaintiff's supervisor constitutes proof of the illegitimate and discriminatory "motivating factor" necessary in a mixed-motives, disparate-treatment claim of sex discrimination. Once the plaintiff makes such a showing, the burden of persuasion shifts to the defendant employer to show that the same employment decision would have been made, even absent the impermissible motivating factor. At this point, whether or not the defendant carries his/her burden, liability may attach. If the defendant is successful, however, damages will not be awarded. This paper supports the unified approach by providing relevant research that shows the connection between sexual harassment and women leaving the workforce. Because one of Title VII's goals is to eliminate sex segregation in the workforce, the unified approach promotes the achievement of the overriding policy of the statute and provides a policy reason for having a broader definition of causation. 108 footnotes