Harassing a Manager

This Labor Prof Blog post on whether a manager can be sexually harassed by subordinates sparks certain concerns:

• If a manager is reponsible for maintaining a harassment-free work environment, then why doesn't the manager simply take appropriate disciplinary action against the harasser? This is not the same as a person who is powerless to correct matters.
• But if the manager does try to take corrective disciplinary action and the employer fails to support such action, then the situation has changed and the employer is vulnerable to a complaint.