As a judge, Kozinski has addressed the topic of sexual harassment in important ways. In 1991, he joined an opinion that decided such cases should be judged from the perspective of the victims, using what was then called the "reasonable woman" standard. The opinion, written by then-Judge Robert R. Beezer, noted pointedly, "Conduct that many men consider unobjectionable may offend many women."Beezer died in 2012. Kozinski himself wrote about sexual harassment in 1992, commenting on how legal remedies could come with unforeseen consequences.He wrote that men "must be aware of the boundaries of propriety and learn to stay well within them," while women "must be vigilant of their rights, but must also have some forgiveness for human foibles: misplaced humor, misunderstanding, or just plain stupidity."He acknowledged, though, that the problem of harassment was a real one."But who knew, who understood, that it was quite so pervasive," Kozinski wrote. "Apparently most women did, while most men did not. It was the best-kept secret of modern times."