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‘Boorish’ Comments Can Create ‘Hostile Environment’

A co-worker’s persistent “boorish” and “moronic” sexual comments, gestures and invitations to plaintiff and other co-workers, whose complaint supervisors allegedly ignored, supported plaintiff’s request for a trial on her hostile environment claim, but the 4th Circuit upholds summary judgment for employer on plaintiff’s retaliatory termination claim. The alleged primary harasser called plaintiff “fresh meat,” made lewd ...

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