AND · 42usc2000e-2:hostile-environment
Harassment so severe or pervasive as to alter the conditions of the victim's employment and create an objectively and subjectively abusive working environment.
Exact element source
compensation, terms, conditions, or privileges of employmentSource:
docroot/ir/usc/title42.jsonl#title42_sec2000e-2; Unicode character offsets [258:318] (end exclusive); SHA-256 7b026a9ac957c5491602d868578271db8730b4c98650f1a4007b2e7430194c8b.Routes and case patterns
| Route | Definition | Merits instance blocks | Distinct merits cases | Examples (up to 3 cases per count group) |
|---|---|---|---|---|
| _whole accepted; provisional (1 case) | The element is decided as a whole: the reasoning turns on no narrower doctrinal sub-question that distinguishes it from any other application of this element. | 0 Satisfied 0; not satisfied 0; excluded context 1 | 0 | Used only in non-merits blocks (1). Excluded context examples:Glenn v. Raymour — 832 F. Supp. 2d 539 (2011) · United States District Court for the Eastern District of Pennsylvania · 2011 — not · waived (42usc2000e-2: author: Fable · historical QA: PASS (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed) · applied/procedural · not counted |
| severe-or-pervasive provisional; 5 observed cases | Whether the conduct was severe or pervasive enough to alter conditions of employment (Harris). | 4 Satisfied 1; not satisfied 3; excluded context 1 | 4 | Ginger v. District of Columbia — 477 F. Supp. 2d 41 (2007) · United States District Court for the District of Columbia · 2007 — not · no-evidence (42usc2000e-2: author: Fable · not independently reviewed) · applied/merits · counted Martinelli v. Bancroft Chophouse, LLC — 357 F. Supp. 3d 95 (2019) · United States District Court for the District of Massachusetts · 2019 — not · no-evidence (42usc2000e-2: author: Flash2 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) · applied/merits · counted Beck v. Figeac Aero N. Am., Inc. — 382 F. Supp. 3d 1170 (2019) · United States District Court for the District of Kansas · 2019 — satisfied · pleaded (42usc2000e-2: author: Flash2 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) · applied/merits · counted Harris v. Forklift Systems, Inc. — 510 U.S. 17 (1993) · Supreme Court of the United States · 1993 — not reached · basis not recorded (42usc2000e-2: author: Fable · historical QA: PASS (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed) · rule-announced/merits · not counted |
How courts decided this element
| Case | Element | Holding and scope | Pattern | Exact source quotations |
|---|---|---|---|---|
| Ginger v. District of Columbia — 477 F. Supp. 2d 41 (2007) · United States District Court for the District of Columbia · 2007 — not · no-evidence (42usc2000e-2: author: Fable · not independently reviewed) | Severe or pervasive hostile or abusive working environment | not Counted merits instance applied / merits basis: no-evidence; claim: (a)(1); 2000e-3(a) | sporadic-anonymous-coworker-graffiti-and-gestures | (1) a drawing placed on Squad 2’s locker that depicts members of the squad as KKK members and has written on the bottom “The Good 01’ Day’s”; (2) the words “KKK,” “Whitey Rules,” or “The Good 01 Boy Squad” written on the chalkboard; (3) receiving Nazi salutes from coworkers; (4) silent treatment by other officers;Source: docroot/ir/caselaw/f_supp_2d_477.jsonl#/f-supp-2d/477/0041-01; Unicode character offsets [29091:29406] (end exclusive); SHA-256 98f9fdfbd29e7eaa93261d6440fe0ed8e4821a6a9a6334e41f0be98ebbbe49e1.Plaintiffs do not allege that any of these incidents were physically threatening, nor do they provide any information about the frequency with which these incidents occurred.Source: docroot/ir/caselaw/f_supp_2d_477.jsonl#/f-supp-2d/477/0041-01; Unicode character offsets [29994:30168] (end exclusive); SHA-256 98f9fdfbd29e7eaa93261d6440fe0ed8e4821a6a9a6334e41f0be98ebbbe49e1.A workplace is hostile for purposes of Title VII only when “the workplace is permeated with discriminatory intimidation, ridicule, and insult that is sufficiently severe or pervasive to alter the conditions of the victim’s employment and create an abusive working environment.”Source: docroot/ir/caselaw/f_supp_2d_477.jsonl#/f-supp-2d/477/0041-01; Unicode character offsets [27252:27529] (end exclusive); SHA-256 98f9fdfbd29e7eaa93261d6440fe0ed8e4821a6a9a6334e41f0be98ebbbe49e1.Whether considered in isolation or taken together, these incidents do not provide sufficiently severe or pervasive conduct to support a hostile work environment claim.Source: docroot/ir/caselaw/f_supp_2d_477.jsonl#/f-supp-2d/477/0041-01; Unicode character offsets [29538:29705] (end exclusive); SHA-256 98f9fdfbd29e7eaa93261d6440fe0ed8e4821a6a9a6334e41f0be98ebbbe49e1. |
| Glenn v. Raymour — 832 F. Supp. 2d 539 (2011) · United States District Court for the Eastern District of Pennsylvania · 2011 — not · waived (42usc2000e-2: author: Fable · historical QA: PASS (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed) | Severe or pervasive hostile or abusive working environment | not Excluded from merits counts applied / procedural basis: waived; claim: (a)(1) | abandoned/claim-not-defended-at-summary-judgment | In response, Glenn fails to even mention his “harassment,” hostile work environment, or retaliation claims in his brief, much less establish his prima facie case for them.Source: docroot/ir/caselaw/f_supp_2d_832.jsonl#/f-supp-2d/832/0539-01; Unicode character offsets [18266:18437] (end exclusive); SHA-256 ad682cd3ab80d3bbd67d0ed1b42af8b4626a1b1756981872f0895f0ffadff61f.Therefore, I deem Glenn to have abandoned these claims by failing to address them in his response to Raymours’ motion for summary judgment.Source: docroot/ir/caselaw/f_supp_2d_832.jsonl#/f-supp-2d/832/0539-01; Unicode character offsets [18438:18577] (end exclusive); SHA-256 ad682cd3ab80d3bbd67d0ed1b42af8b4626a1b1756981872f0895f0ffadff61f. |
| Martinelli v. Bancroft Chophouse, LLC — 357 F. Supp. 3d 95 (2019) · United States District Court for the District of Massachusetts · 2019 — not · no-evidence (42usc2000e-2: author: Flash2 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | Severe or pervasive hostile or abusive working environment | not Counted merits instance applied / merits basis: no-evidence; claim: (a)(1) | one-sexual-remark-by-manager-then-perceived-ostracism-by-other-managers | He testified that he was subjected to a generally uncomfortable atmosphere at the restaurant and that he felt as though the managers were ignoring or avoiding him.Source: docroot/ir/caselaw/f_supp_3d_357.jsonl#/f-supp-3d/357/0095-01; Unicode character offsets [11084:11247] (end exclusive); SHA-256 e341ff3eb37061e227f597bc3535d6b9e36a2d9af8bbde04a17f6618a4b5caf3.Plaintiff concedes that no member of management, other than Seznec, ever said anything sexually offensive to him and that after his complaint Seznec never made any other sexual comments to him.Source: docroot/ir/caselaw/f_supp_3d_357.jsonl#/f-supp-3d/357/0095-01; Unicode character offsets [544:737] (end exclusive); SHA-256 e341ff3eb37061e227f597bc3535d6b9e36a2d9af8bbde04a17f6618a4b5caf3.Moreover, Martinelli admits that he did not find Seznec's remark to be offensive nor does he allege that it interfered in any way with his work performance.Source: docroot/ir/caselaw/f_supp_3d_357.jsonl#/f-supp-3d/357/0095-01; Unicode character offsets [10812:10968] (end exclusive); SHA-256 e341ff3eb37061e227f597bc3535d6b9e36a2d9af8bbde04a17f6618a4b5caf3.When asked about specific instances of harassment, however, Martinelli could only recall one time when a few of the managers seemed to be annoyed with him when he asked them where the wine was located.Source: docroot/ir/caselaw/f_supp_3d_357.jsonl#/f-supp-3d/357/0095-01; Unicode character offsets [11248:11449] (end exclusive); SHA-256 e341ff3eb37061e227f597bc3535d6b9e36a2d9af8bbde04a17f6618a4b5caf3.A single, isolated incident of harassment, however, is ordinarily insufficient to establish a claim for hostile work environment unless the incident was particularly egregious and the employee must demonstrate how his or her ability to work was negatively affected.Source: docroot/ir/caselaw/f_supp_3d_357.jsonl#/f-supp-3d/357/0095-01; Unicode character offsets [6691:6956] (end exclusive); SHA-256 e341ff3eb37061e227f597bc3535d6b9e36a2d9af8bbde04a17f6618a4b5caf3.With respect to the alleged comment by Seznec, that single, isolated remark was not sufficiently egregious to constitute severe sexual harassment and plaintiff concedes that it was the only instance of alleged sexual harassment by Seznec.Source: docroot/ir/caselaw/f_supp_3d_357.jsonl#/f-supp-3d/357/0095-01; Unicode character offsets [10573:10811] (end exclusive); SHA-256 e341ff3eb37061e227f597bc3535d6b9e36a2d9af8bbde04a17f6618a4b5caf3.That single instance of alleged harassment or a general discomfort falls far short of conduct that is normally required to establish a hostile work environment claim.Source: docroot/ir/caselaw/f_supp_3d_357.jsonl#/f-supp-3d/357/0095-01; Unicode character offsets [11450:11616] (end exclusive); SHA-256 e341ff3eb37061e227f597bc3535d6b9e36a2d9af8bbde04a17f6618a4b5caf3. |
| Beck v. Figeac Aero N. Am., Inc. — 382 F. Supp. 3d 1170 (2019) · United States District Court for the District of Kansas · 2019 — satisfied · pleaded (42usc2000e-2: author: Flash2 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | Severe or pervasive hostile or abusive working environment | satisfied Counted merits instance applied / merits basis: pleaded; claim: (a) The court notes the frequency of the conduct is unclear from the complaint but infers it from HR's acknowledgment; the conduct need not have been directed at the plaintiff. | manager's-repeated-anti-american-slurs-and-table-striking-outbursts-over-three-months | Beck, who is American, alleges that during that time her manager, Hocine Benaoum, who is French, referred to some employees as "stupid Americans," referred to American employees as "f*cking stupid," and referred to one employee as "nothing but a God D*mned American buyer."Source: docroot/ir/caselaw/f_supp_3d_382.jsonl#/f-supp-3d/382/1170-01; Unicode character offsets [866:1139] (end exclusive); SHA-256 bf0e94769a9c76f63453f558a56b227b214ef9156a48d4a1c1aac4c3a3426919.Beck alleges that Benaoum displayed violent tendencies toward American employees but not French employees, stating that Benaoum would regularly "strike tables, walls, and other things while screaming at American employees."Source: docroot/ir/caselaw/f_supp_3d_382.jsonl#/f-supp-3d/382/1170-01; Unicode character offsets [1140:1363] (end exclusive); SHA-256 bf0e94769a9c76f63453f558a56b227b214ef9156a48d4a1c1aac4c3a3426919.The conduct requires more than "run-of-the-mill boorish, juvenile, or annoying behavior"-rather, severe discriminatory conduct must permeate the workplace.Source: docroot/ir/caselaw/f_supp_3d_382.jsonl#/f-supp-3d/382/1170-01; Unicode character offsets [7460:7615] (end exclusive); SHA-256 bf0e94769a9c76f63453f558a56b227b214ef9156a48d4a1c1aac4c3a3426919.This suggests the conduct complained of was ongoing rather than isolated incidences.Source: docroot/ir/caselaw/f_supp_3d_382.jsonl#/f-supp-3d/382/1170-01; Unicode character offsets [8363:8447] (end exclusive); SHA-256 bf0e94769a9c76f63453f558a56b227b214ef9156a48d4a1c1aac4c3a3426919.Beck has brought enough factual allegations to plausibly claim hostile work environment under Title VII.Source: docroot/ir/caselaw/f_supp_3d_382.jsonl#/f-supp-3d/382/1170-01; Unicode character offsets [7832:7936] (end exclusive); SHA-256 bf0e94769a9c76f63453f558a56b227b214ef9156a48d4a1c1aac4c3a3426919. |
| Mahler v. First Dakota Title Ltd. P'ship — 931 F.3d 799 (2019) · United States Court of Appeals for the Eighth Circuit · 2019 — not · no-evidence (42usc2000e-2: author: Flash2 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | Severe or pervasive hostile or abusive working environment | not Counted merits instance applied / merits basis: no-evidence; claim: (a) Two grounds in one paragraph: the conduct was not subjectively unwelcome (primary), and "even if" unwelcome, a single incident is not severe (alternative). | single-off-color-email-that-plaintiff-said-did-not-offend-her | "The proper inquiry is whether the plaintiff indicated by [her] conduct that the alleged harassment was unwelcome."Source: docroot/ir/caselaw/f3d_931.jsonl#/f3d/931/0799-01; Unicode character offsets [13446:13561] (end exclusive); SHA-256 3e8dacc83ce7e502f47d50a01ce4f274c8e9529a0841652cd8d421c35b43d57a.In February 2015, Anderson emailed Mahler some off-color jokes, explaining "Hopefully the following will not offend you."Source: docroot/ir/caselaw/f3d_931.jsonl#/f3d/931/0799-01; Unicode character offsets [1726:1847] (end exclusive); SHA-256 3e8dacc83ce7e502f47d50a01ce4f274c8e9529a0841652cd8d421c35b43d57a.However, she responded to Anderson's email, "No offense taken and thank you I did get a good laugh out of it."Source: docroot/ir/caselaw/f3d_931.jsonl#/f3d/931/0799-01; Unicode character offsets [13767:13877] (end exclusive); SHA-256 3e8dacc83ce7e502f47d50a01ce4f274c8e9529a0841652cd8d421c35b43d57a.After she was terminated, she texted a friend that she was not sexually harassed, only "fired for reporting it."Source: docroot/ir/caselaw/f3d_931.jsonl#/f3d/931/0799-01; Unicode character offsets [13878:13990] (end exclusive); SHA-256 3e8dacc83ce7e502f47d50a01ce4f274c8e9529a0841652cd8d421c35b43d57a.Because her actions demonstrate that she did not personally experience offensive or unwelcome harassment, her claim fails.Source: docroot/ir/caselaw/f3d_931.jsonl#/f3d/931/0799-01; Unicode character offsets [13991:14113] (end exclusive); SHA-256 3e8dacc83ce7e502f47d50a01ce4f274c8e9529a0841652cd8d421c35b43d57a.Even if the email were unwelcome harassment, this single incident is not severe enough to alter the conditions of her employment.Source: docroot/ir/caselaw/f3d_931.jsonl#/f3d/931/0799-01; Unicode character offsets [14310:14439] (end exclusive); SHA-256 3e8dacc83ce7e502f47d50a01ce4f274c8e9529a0841652cd8d421c35b43d57a. |
| Harris v. Forklift Systems, Inc. — 510 U.S. 17 (1993) · Supreme Court of the United States · 1993 — not reached (42usc2000e-2: author: Fable · historical QA: PASS (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed) | Severe or pervasive hostile or abusive working environment | not_reached Excluded from merits counts rule-announced / merits claim: (a)(1) Court fixes the test (objective + subjective abusiveness, totality of circumstances; no psychological-injury requirement) but does not apply it: whether the president's conduct met it is left for remand. The trial court's not-satisfied finding is vacated because it rested on the wrong standard. The `held` lines reject the lower court's test; they are not an application to facts. | psychological-injury-not-required | Hardy told Harris on several occasions, in the presence of other employees, “You’re a woman, what do you know” and “We need a man as the rental manager”; at least once, he told her she was “a dumb ass woman.”Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0017-01; Unicode character offsets [653:861] (end exclusive); SHA-256 d1ea22ac767a8da9f8196f8e0b5a1a9926fdbf322dd6be788952d6040b67ddef.Again in front of others, he suggested that the two of them “go to the Holiday Inn to negotiate [Harris’] raise.”Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0017-01; Unicode character offsets [891:1004] (end exclusive); SHA-256 d1ea22ac767a8da9f8196f8e0b5a1a9926fdbf322dd6be788952d6040b67ddef.Hardy occasionally asked Harris and other female employees to get coins from his front pants pocket.Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0017-01; Unicode character offsets [1019:1119] (end exclusive); SHA-256 d1ea22ac767a8da9f8196f8e0b5a1a9926fdbf322dd6be788952d6040b67ddef.But in early September, Hardy began anew: While Harris was arranging a deal with one of Forklift’s customers, he asked her, again in front of other employees, “What did you do, promise the guy . . . some [sex] Saturday night?”Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0017-01; Unicode character offsets [1605:1831] (end exclusive); SHA-256 d1ea22ac767a8da9f8196f8e0b5a1a9926fdbf322dd6be788952d6040b67ddef.Conduct that is not severe or pervasive enough to create an objectively hostile or abusive work environment — an environment that a reasonable person would find hostile or abusive — is beyond Title VII’s purview.Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0017-01; Unicode character offsets [5643:5855] (end exclusive); SHA-256 d1ea22ac767a8da9f8196f8e0b5a1a9926fdbf322dd6be788952d6040b67ddef.if the victim does not subjectively perceive the environment to be abusive, the conduct has not actually altered the conditions of the victim’s employment, and there is no Title VII violation.Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0017-01; Unicode character offsets [5866:6058] (end exclusive); SHA-256 d1ea22ac767a8da9f8196f8e0b5a1a9926fdbf322dd6be788952d6040b67ddef.So long as the environment would reasonably be perceived, and is perceived, as hostile or abusive, Meritor, supra, at 67, there is no need for it also to be psychologically injurious.Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0017-01; Unicode character offsets [7638:7821] (end exclusive); SHA-256 d1ea22ac767a8da9f8196f8e0b5a1a9926fdbf322dd6be788952d6040b67ddef.These may include the frequency of the discriminatory conduct; its severity; whether it is physically threatening or humiliating, or a mere offensive utterance; and whether it unreasonably interferes with an employee’s work performance.Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0017-01; Unicode character offsets [8291:8527] (end exclusive); SHA-256 d1ea22ac767a8da9f8196f8e0b5a1a9926fdbf322dd6be788952d6040b67ddef.We therefore believe the District Court erred in relying on whether the conduct “seriously affect[ed] plaintiff’s psychological well-being” or led her to “suffe[r] injury.”Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0017-01; Unicode character offsets [7173:7345] (end exclusive); SHA-256 d1ea22ac767a8da9f8196f8e0b5a1a9926fdbf322dd6be788952d6040b67ddef.The District Court’s application of these incorrect standards may well have influenced its ultimate conclusion, especially given that the court found this to be a “close case,”Source: docroot/ir/caselaw/us_510.jsonl#/us/510/0017-01; Unicode character offsets [9400:9576] (end exclusive); SHA-256 d1ea22ac767a8da9f8196f8e0b5a1a9926fdbf322dd6be788952d6040b67ddef. |
Court interpretations
interpretation
Conduct that is not severe or pervasive enough to create an objectively hostile or abusive work environment — an environment that a reasonable person would find hostile or abusive — is beyond Title VII’s purview.
Harris v. Forklift Systems, Inc. — 510 U.S. 17 (1993) · Supreme Court of the United States · 1993 (42usc2000e-2: author: Fable · historical QA: PASS (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed)
Conduct that is not severe or pervasive enough to create an objectively hostile or abusive work environment — an environment that a reasonable person would find hostile or abusive — is beyond Title VII’s purview.Source:
docroot/ir/caselaw/us_510.jsonl#/us/510/0017-01; Unicode character offsets [5643:5855] (end exclusive); SHA-256 d1ea22ac767a8da9f8196f8e0b5a1a9926fdbf322dd6be788952d6040b67ddef.Harassment so severe or pervasive as to alter the conditions of the victim's employment and create an objectively and subjectively abusive working environment.
interpretation
if the victim does not subjectively perceive the environment to be abusive, the conduct has not actually altered the conditions of the victim’s employment, and there is no Title VII violation.
Harris v. Forklift Systems, Inc. — 510 U.S. 17 (1993) · Supreme Court of the United States · 1993 (42usc2000e-2: author: Fable · historical QA: PASS (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed)
if the victim does not subjectively perceive the environment to be abusive, the conduct has not actually altered the conditions of the victim’s employment, and there is no Title VII violation.Source:
docroot/ir/caselaw/us_510.jsonl#/us/510/0017-01; Unicode character offsets [5866:6058] (end exclusive); SHA-256 d1ea22ac767a8da9f8196f8e0b5a1a9926fdbf322dd6be788952d6040b67ddef.Harassment so severe or pervasive as to alter the conditions of the victim's employment and create an objectively and subjectively abusive working environment.
interpretation
So long as the environment would reasonably be perceived, and is perceived, as hostile or abusive, Meritor, supra, at 67, there is no need for it also to be psychologically injurious.
Harris v. Forklift Systems, Inc. — 510 U.S. 17 (1993) · Supreme Court of the United States · 1993 (42usc2000e-2: author: Fable · historical QA: PASS (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed)
So long as the environment would reasonably be perceived, and is perceived, as hostile or abusive, Meritor, supra, at 67, there is no need for it also to be psychologically injurious.Source:
docroot/ir/caselaw/us_510.jsonl#/us/510/0017-01; Unicode character offsets [7638:7821] (end exclusive); SHA-256 d1ea22ac767a8da9f8196f8e0b5a1a9926fdbf322dd6be788952d6040b67ddef.Harassment so severe or pervasive as to alter the conditions of the victim's employment and create an objectively and subjectively abusive working environment.
interpretation
These may include the frequency of the discriminatory conduct; its severity; whether it is physically threatening or humiliating, or a mere offensive utterance; and whether it unreasonably interferes with an employee’s work performance.
Harris v. Forklift Systems, Inc. — 510 U.S. 17 (1993) · Supreme Court of the United States · 1993 (42usc2000e-2: author: Fable · historical QA: PASS (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed)
These may include the frequency of the discriminatory conduct; its severity; whether it is physically threatening or humiliating, or a mere offensive utterance; and whether it unreasonably interferes with an employee’s work performance.Source:
docroot/ir/caselaw/us_510.jsonl#/us/510/0017-01; Unicode character offsets [8291:8527] (end exclusive); SHA-256 d1ea22ac767a8da9f8196f8e0b5a1a9926fdbf322dd6be788952d6040b67ddef.Harassment so severe or pervasive as to alter the conditions of the victim's employment and create an objectively and subjectively abusive working environment.
interpretation
A workplace is hostile for purposes of Title VII only when “the workplace is permeated with discriminatory intimidation, ridicule, and insult that is sufficiently severe or pervasive to alter the conditions of the victim’s employment and create an abusive working environment.”
Ginger v. District of Columbia — 477 F. Supp. 2d 41 (2007) · United States District Court for the District of Columbia · 2007 (42usc2000e-2: author: Fable · not independently reviewed)
A workplace is hostile for purposes of Title VII only when “the workplace is permeated with discriminatory intimidation, ridicule, and insult that is sufficiently severe or pervasive to alter the conditions of the victim’s employment and create an abusive working environment.”Source:
docroot/ir/caselaw/f_supp_2d_477.jsonl#/f-supp-2d/477/0041-01; Unicode character offsets [27252:27529] (end exclusive); SHA-256 98f9fdfbd29e7eaa93261d6440fe0ed8e4821a6a9a6334e41f0be98ebbbe49e1.Harassment so severe or pervasive as to alter the conditions of the victim's employment and create an objectively and subjectively abusive working environment.
not-required
Tangible psychological injury or nervous breakdown (Harris v. Forklift Systems, Inc., 510 U.S. 17 (1993))
No source quotation recorded.