In what circumstances have courts found that comments made by a supervisor to a female employee constitute a hostile work environment?

MultiRegion, United States of America

The following excerpt is from Fried v. Wynn Las Vegas, LLC, 20-15710 (9th Cir. 2021):

In Kortan v. California Youth Authority, 217 F.3d 1104 (9th Cir. 2000), a female employee brought a hostile work environment claim based on her supervisor's misogynistic comments. Id. at 1106-08. The supervisor referred to an employee as a "regina" and said that the employee "laughs like a hyena." Id. at 1107. The same supervisor referred to another employee as a "madonna," a "regina," and a

"castrating bitch," and to women generally as "bitches" and "histrionics." Id. We held that these crass and denigrating comments were not severe enough to create a hostile work environment, in part because the comments were concentrated on one occasion. See id. at 1110-11.

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