Workplace Harassment - Severe OR Pervasive, Not Both.

The district court in Seale v. Madison Cty., Case No. 5:11-CV-0278 (N.D.N.Y., Feb. 17, 2015) (Slip. Op. at 16), makes clear that “in order to establish [a] claim for hostile work environment, a plaintiff need not show that her “working environment was both severe and pervasive; only that it was sufficiently severe or sufficiently pervasive, or a sufficient combination of these elements, to have altered her working conditions.” (Citations omitted.)