Hostile work environment harassment occurs when unwelcome sexual conduct unreasonably interferes with a person’s performance or creates an intimidating, hostile, or offensive working environment. Meritor Savs. Bank FSB v. Vinson, 477 U.S. 57, 65, 106 S.Ct. 2399, 2404, 91 L.Ed.2d 49 (1986) (quoting 29 C.F.R. § 1604.11(a)(3)). In order to be actionable, the harassment must be so severe or pervasive that it alters the conditions of the victim’s employment and creates an abusive environment. Id. at 67.
In Harris v. Forklift Sys., Inc., 510 U.S. 17, 114 S.Ct. 367, 126 L.Ed.2d 295 (1993), our Supreme Court clarified the elements of a discrimination claim resulting from a hostile work environment. In order to fall within the purview of Title VII, the conduct in question must be severe and pervasive enough to create an “objectively hostile or abusive work environment—an environment that a reasonable person would find hostile—and an environment the victim-employee subjectively perceives as abusive or hostile.” Id. at 21-22, 114 S.Ct. at 370-71.
In determining whether an environment is hostile or abusive, we must look at numerous factors, including “the frequency of the discriminatory conduct; its severity; whether it is physically threatening or humiliating, or a mere offensive utterance; whether it unreasonably interferes with an employee’s work performance.” Id. at 23, 114 S.Ct. at 371. The Supreme Court recently reaffirmed Harris’ “severe and pervasive” test in Faragher v. City of Boca Raton, 524 U.S. 775, 783, 118 S.Ct. 2275, 2283, 141 L.Ed.2d 662 (1998), and Burlington Indus., Inc. v. Ellerth, 524 U.S. 742, 753, 118 S.Ct. 2257, 2265, 141 L.Ed.2d 633 (1998).