Work place harassment is still with us. And, courts still struggle with the term “severe or pervasive.” To rise to the level of work place harassment, conduct must be “severe or pervasive.” In Sanders v. Christus Santa Rosa PASC, 995 F.Supp. 2d 626 (W.D. Tex. 2014), the court looked at the totality of the circumstances and found there was issue of fact whether the harassment was severe or pervasive. Stephanie Sanders worked as a nurse at Christus Santa Rosa Hospitak. Dr. Michael Decherd made numerous sexual comments to the nurse. He showed her a video of a horse sodomizing a woman. He frequently sought her out, hugged her, showed a picture of her to a subordinate, and asked her to friend him on Facebook. He showed her a picture of a man performing oral sex on a woman and said he had changed his mind about oral sex.
The hospital filed a