In a recent Minnesota Federal District case, the Court made it clear that a hostile work environment cause of action is limited to extreme work conditions.  In order to prevail, a plaintiff must show harassment that is sufficiently severe or pervasive as to affect a term, condition or privilege of employment by creating an objectively hostile or abusive environment.   The Court looked to the frequency of the discriminating conduct and its severity to determine whether it was physically threatening or humiliating, or a mere offensive utterance.  In this case, the harassing employee tugged on the plaintiff’s shorts, ran his fingers through her hair, asked inappropriate questions about her sex life and breasts, and made improper sexual gestures and invitations, but it was unclear whether this was a single event or a series of events.  Citing another case, the Court suggested that these actions may have been “boorish, chauvinistic, and decidedly immature,” but did not create a hostile environment.  In this case, even if the determination had been that the environment was hostile, the employer took immediate remedial action, which would have provided the employer with protection.  Takkunen v. Sappi Cloquet, LLC (Minn. D.C. 2009).