California, United States of America
The following excerpt is from Miorelli v. Ownership, A145839 (Cal. App. 2017):
41. Harris v. Forklift Systems, Inc., supra, 510 U.S. 17, addressed the definition of "a discriminatorily 'abusive work environment' (also known as a 'hostile work environment') under Title VII of the Civil Rights Act of 1964." At page 21, the point page in appellants' citation, the court explained its reaffirmation of a standard that "takes a middle path between making actionable any conduct that is merely offensive and requiring the conduct to cause a tangible psychological injury." (Id. at p. 21.)
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