California, United States of America
The following excerpt is from Adetuyi v. City, A124936 (Cal. App. 2011):
" 'In determining what constitutes "sufficiently pervasive" harassment, the courts have held that acts of harassment cannot be occasional, isolated, sporadic, or trivial, rather the plaintiff must show a concerted pattern of harassment of a repeated, routine or a generalized nature. [Citation.] []... 'The required level of severity or seriousness "varies inversely with the pervasiveness or frequency of the conduct." [Citation.] "[S]imple teasing, offhand comments, and isolated incidents (unless extremely serious) will not amount to discriminatory changes in the terms and conditions of employment." [Citation.]' " (Mokler v. County of Orange, supra, 157 Cal.App.4th at p. 142.)
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