11.   Employees today often claim they are victims of a hostile work environment that could include persistent e-mail requests for dates, racy jokes or pornography downloaded from the Internet.

12.   For the MCAD to fail to hold Northwest Airlines accountable for tolerating such a hostile work environment is to suggest that the harassment directed at Susan Tarasciewicz was unique.

13.   Garth Fundis, chairman of the academy board, said that the investigation was complete and that it revealed no sexual harassment, sex discrimination or hostile work environment.

14.   He also cites a hostile work environment, including crude drawings and racial jokes.

15.   If a supervisor creates a hostile work environment, however, he does not act for the employer.

16.   In addition, the court said, a single instance would not necessarily qualify as a hostile work environment.

17.   In the second situation, generally called a hostile work environment case, there is a sexually hostile environment, marked by severe or pervasive conduct.

18.   In the case of sexually explicit material, the usage could have fostered a hostile work environment actionable under civil rights laws, the report cautioned.

19.   Indeed, a hostile work environment is antithetical to the interest of the employer.

20.   Instead, they said, a successfull suit will have to show a pervasive pattern of humiliating, offensive, unwelcome behavior that creates a hostile work environment.