In Anastasia v. Cushman Wakefield, 2011 WL 6241093 (3d Cir., Dec. 15, 2011), the Third Circuit Court of Appeals affirmed that a co-worker’s unsuccessful confession of romantic interest in the plaintiff, and his frequent subsequent apologies to plaintiff for his unrequited romantic interest, were insufficient to establish a claim of hostile work environment and/or constructive discharge. The Appellate Division confirmed that such conduct was neither severe nor pervasive enough to establish a hostile work environment, and was not sufficiently outrageous, coercive or unconscionable to establish a constructive discharge claim.
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