Shaw v. Access Ohio

{¶ 42} I write separately only to clarify any implications in our opinion that a hostile work environment claim requires that the employee's work performance must be affected and/or that the offensive remarks be made by an agent or decision-maker of the employer.

{¶ 43} As noted by the United States Supreme Court, "Title VII bars conduct that would seriously affect a reasonable person's psychological well-being, but the statute is not limited to such conduct. So long as the environment would reasonably be perceived, and is perceived, as hostile or abusive, there is no need for it also to be…