What is the current state of the law on harassment?

necessary to performance of a supervisor's job'" (Reno v. Baird (1998) 18 Cal.4th 640, 645 (Reno).) "'[H]arassment consists of a type of conduct not necessary for performance of a supervisory job. Instead, harassment consists of conduct outside the scope of necessary job performance, conduct presumably engaged in for personal gratification, because of meanness or bigotry, or for other personal motives. Harassment is not conduct of a type necessary for management of the employer's business or performance of the supervisory employee's job.'" (Id. at pp. 645-646.) "'[C]ommonly necessary personnel management actions such as hiring and firing . . . do not come within the meaning of harassment.'" (Id. at pp. 646-647.)