In Dziedzic v. State University of New York at Oswego (decided Dec. 19, 2014), the Northern District of New York reiterated that, in order to establish a hostile work environment under Title VII of the Civil Rights Act of 1964, a plaintiff must establish two elements:
 the workplace is permeated with discriminatory intimidation, ridicule, and insult … that is sufficiently severe or pervasive to alter the conditions of the victim’s employment and create an abusive working environment. … Usually, a single isolated instance of harassment will not suffice to establish a hostile work environment unless it was extraordinarily severe. … Thus, the plaintiff must demonstrate either that a single incident was extraordinarily severe, or that a series of incidents were sufficiently continuous and concerted to have altered the conditions of her working environment. …
 [A] specific basis exists for imputing the conduct that created the hostile environment to the employer. … When the source of the alleged harassment is a co-worker, the plaintiff must demonstrate that the employer failed to provide a reasonable avenue for complaint or if it knew, or in the exercise of reasonable care should have known, about the harassment yet failed to take appropriate remedial action.
In this case, plaintiff loses. Why? The court tells us:
Plaintiff has not alleged that any of the seven acts within the statutory period were motivated by a discriminatory animus toward her because of her protected status, nor has she alleged that a single incident was extraordinarily severe or that the complained-of incidents in their entirety were sufficiently severe or pervasive to alter the conditions of her employment. Accordingly, the Court grants Defendant’s motion for summary with respect to Plaintiff’s Title VII hostile work environment claim.