For a violation to impose liability, the conduct must create a work environment that would be intimidating, hostile, or offensive to a reasonable person.
[4] A hostile work environment may also be created when management acts in a manner designed to make an employee quit in retaliation for some action.
It falls under the impression that a ‘reasonable woman’ does not get sexually harassed at work, thus creating a hostile workplace.
The new standard was behavior a reasonable woman would think was extreme enough to change the terms of employment and establish a hostile work environment.
To establish whether the situation is actionable the "totality of circumstances" must be weighed with an eye to determining "that the harassment affected a term, condition, or privilege of employment in that it was sufficiently severe or pervasive to alter the condition of the victim's employment and create an abusive working environment".
When an employee claims that a hostile work environment is an adverse employment action, the legal analysis is similar to the burdens of proof described above.