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    Office of the Circuit Executive 
    U.S. Court of Appeals for the Ninth Circuit 
    
    
    Case Name:
    BROOKS V CITY OF SAN MATEO
    Case Number:
                              Date Filed:
    98-15818
                              10/23/00
    
    
    
    FOR PUBLICATION 
    UNITED STATES COURT OF APPEALS
    FOR THE NINTH CIRCUIT 
    
    
    PATRICIA A. BROOKS,
    
    Plaintiff-Appellant, 
                                                No. 98-15818
    v.
                                                D.C. No. CV-96-03753-WHO
    CITY OF SAN MATEO, a municipal 
                                                ORDER AND
    corporation; SAN MATEO POLICE
                                                OPINION
    DEPARTMENT; JOHN STANGL, Chief
    
    of Police; STEVEN SELVAGGIO,
    
    Defendants-Appellees. 
    
    
    
    Appeal from the United States District Court
    for the Northern District of California
    William H. Orrick, Jr., District Judge, Presiding
    
    Argued and Submitted 
    May 14, 1999--San Francisco, California
    
    Filed October 23, 2000 
    
    Before: Harlington Wood, Jr.,* Alex Kozinski and
    Pamela Ann Rymer, Circuit Judges.
    Opinion by Judge Kozinski
    
    _________________________________________________________________
    *The Honorable Harlington Wood, Jr., Senior Circuit Judge for the Sev- 
    enth Circuit Court of Appeals, sitting by designation.
    
    13365
    
    
    COUNSEL
    
    John F. Prentice and Sheila A. Reid, Prentice & Scott, San
    Francisco, California, argued the cause for the plaintiff-
    appellant.
    
    13369
    
    Nancy E. Pritikin, Littler, Mendelson, San Francisco, Califor-
    nia, argued the cause for defendants-appellees, City of San
    Mateo, et al. With her on the briefs were Ronald J. Holland
    and Susan A.P. Woodhouse.
    
    Alison Berry-Wilkinson, Carroll, Burdick and McDonough,
    San Francisco, California, argued the cause for defendant-
    appellee Steven Selvaggio. With her on the briefs was Kamili
    A. Williams.
    _________________________________________________________________
    ORDER
    
    The opinion filed June 5, 2000, and reported at 214 F.3d
    1082, is withdrawn and superseded by the attached opinion.
    The petition for rehearing is otherwise denied. The full court
    was advised of the petition for rehearing en banc. A judge of
    the court requested a vote on whether to rehear the matter en
    banc, but the matter failed to receive a majority of the votes
    of the nonrecused active judges in favor of en banc consider-
    ation. Fed. R. App. P. 35. The petition for rehearing en banc
    is denied.
    _________________________________________________________________
    OPINION
    
    KOZINSKI , Circuit Judge:
    We consider the legal implications of a single, rather unsa-
    vory, episode of workplace sexual harassment.
    
    I
    Our story begins when Patricia Brooks, a telephone dis-
    patcher for the City of San Mateo, California, and her
    coworker, senior dispatcher Steven Selvaggio, manned the
    city's Communications Center, taking 911 calls on the eve-
    
    13370
    
    ning shift. At some point during the evening, Selvaggio
    approached Brooks as she was taking a call. He placed his
    hand on her stomach and commented on its softness and sexi-
    ness. Brooks told Selvaggio to stop touching her and then
    forcefully pushed him away. Perhaps taking this as encour-
    agement, Selvaggio later positioned himself behind Brooks's
    chair, boxing her in against the communications console as
    she was taking another 911 call. He forced his hand under-
    neath her sweater and bra to fondle her bare breast. After ter-
    minating the call, Brooks removed Selvaggio's hand again
    and told him that he had "crossed the line." To this, Selvaggio 
    responded "you don't have to worry about cheating[on your
    husband], I'll do everything." Selvaggio then approached
    Brooks as if he would fondle her breasts again. Fortunately,
    another dispatcher arrived at this time, and Selvaggio ceased
    his behavior. Soon thereafter Selvaggio took a break and left
    the building. Brooks immediately reported the incident and,
    the following day, the city placed Selvaggio on administrative
    leave pending an investigation.
    
    This, it turned out, was not the first time Selvaggio had
    made improper advances to co-workers. At least two other
    female employees, including Pat P., another senior dispatcher,
    had been subjected to similar treatment from Selvaggio. How-
    ever, Selvaggio's earlier victims had not reported his miscon-
    duct. Only after the city launched its investigation into
    Brooks's allegations did these other incidents come to light.
    While Selvaggio denied any misconduct, the investigation
    adopted Brooks's version of events and concluded that
    Selvaggio had violated the city's sexual harassment policy.
    Selvaggio resigned after the city initiated termination pro-
    ceedings against him. He later pled no contest to misdemea-
    nor sexual assault charges and spent 120 days in jail.
    Despite the city's prompt remedial action, Brooks had trou-
    ble recovering from the incident. She took a leave of absence
    immediately afterward and began seeing a psychologist. She
    
    13371
    
    returned to work six months later. According to Brooks, her
    work environment had changed dramatically: The male
    employees ostracized her and her supervisors mistreated her.
    Brooks alleges that she had trouble getting her desired work
    shift and preferred vacation dates, while other employees with
    less seniority got their preferences. She also alleges that the
    city delayed approval of her sick leave benefits, reprimanded
    her for conduct it overlooked in other employees 1 and gave
    her an unwarranted negative performance evaluation. Brooks
    signed the evaluation but indicated that she would appeal it.
    She submitted a written appeal which expressed her view that
    the evaluation was intended to retaliate against her for com-
    plaining about Selvaggio's behavior. While the city was con-
    sidering her appeal, Brooks left work and never returned.
    Brooks obtained right to sue notices from the EEOC and
    the California Department of Fair Employment and Housing.
    She then sued the city, the Police Department and its chief,
    John Stangl, for sexual harassment and retaliatory discrimina-
    tion in violation of Title VII of the Civil Rights Act, see 42 
    U.S.C. ' 2000e et. seq. , and the California Fair Employment
    and Housing Act (FEHA), see Cal. Gov. Code ' 12940 et. seq. 2
    All defendants moved for summary judgment.
    _________________________________________________________________
    1 Brooks has not renewed her argument that the reprimand was retalia-
    tory. See Smith v. Marsh, 194 F.3d 1045, 1052 (9th Cir. 1999) ("[O]n
    appeal, arguments not raised by a party in its opening brief are deemed 
    waived.") (citing Brookfield Communications, Inc. v. West Coast Enter-
    tainment Corp. , 174 F.3d 1036, 1046 n.7 (9th Cir.1999)).
    
    2 Brooks also named Selvaggio as a defendant in her FEHA complaint.
    Unlike Title VII, FEHA grants victims a cause of action for discrimination 
    practiced by "any other person" in addition to that practiced solely by
    employers. Compare 42 U.S.C. ' 2000e-2(a) with Cal. Govt. Code
    ' 12940(h). Nonetheless, the California Supreme Court has recently held 
    that FEHA, like Title VII, does not support a claim of harassment against 
    a fellow employee. See Carrisales v. Department of Corrections , 21 Cal.
    4th 1132, 1140 (1999) ("Consistent with the FEHA's primary concern 
    with unlawful employment practices , it does not also impose personal lia-
    bility for harassment on nonsupervisory coworkers."). Thus, Selvaggio 
    cannot be held liable unless senior dispatchers are supervisors. We con- 
    clude they are not. See note 6 infra.
    
    13372
    
    The district court held that Selvaggio's assault of Brooks in
    the Communications Center was not severe enough to give
    rise to a hostile work environment claim. As for Brooks's
    retaliation claims, the district court held that she failed to
    show that she had suffered any adverse employment conse-
    quences. Based on these rulings, the district court granted the
    summary judgment motion. 
    
    On appeal, Brooks complains that the district court erred in
    ruling that the sexual assault was not sufficient to create a
    hostile work environment. She also argues that the city is lia-
    ble under FEHA and Title VII for failing to take steps to pre-
    vent Selvaggio's misconduct of which it had actual or
    constructive notice. Finally, Brooks claims that the district
    court erred in finding no adverse job action to support her
    retaliation claim. While Brooks argues that she was subjected
    to sexual discrimination under Title VII as well as FEHA, we
    need only assess her claim under federal law because Title
    VII and FEHA operate under the same guiding principles.3
    
    II
    Title VII prohibits employment discrimination based on
    any of its enumerated grounds: " `race, color, religion, sex, or 
    national origin.' " Harris v. Forklift Sys., Inc. , 510 U.S. 17, 21
    (1993) (quoting 42 U.S.C. ' 2000e-2(a)(1)). Sexual harass-
    
    _________________________________________________________________
    3 See Beyda v. City of Los Angeles, 65 Cal. App. 4th 511, 517 (Cal. Ct. 
    App. 1998) ("Although the wording of title VII differs in some particulars 
    from the wording of FEHA, the antidiscriminatory objectives and overrid- 
    ing public policy purposes of the two acts are identical. In an area of 
    emerging law, such as employment discrimination, it is appropriate to con- 
    sider federal cases interpreting title VII.") (internal quotation marks and
    citations omitted); Okoli v. Lockheed Tech. Operations Co. , 36 Cal. App.
    4th 1607, 1614 n.3 (Cal. Ct. App. 1995) ("Since the antidiscrimination 
    objectives and public policy purposes of [FEHA and Title VII] are the 
    same, we may rely on federal decisions to interpret analogous parts of the 
    state statute.") (quoting Sandhu v. Lockheed Missiles & Space Co., 26 Cal.
    App. 4th 846, 851 (Cal. Ct. App. 1994)).
    
    13373
    
    ment is a species of gender discrimination: Harassing an
    employee on account of sex is, conceptually, the same as
    refusing to hire on account of sex, or paying less for the same
    work, or imposing more onerous duties for the same pay. In
    each such case, the employer violates Title VII by offering
    terms and conditions to employees of one gender that are less
    favorable than those it offers to employees of the other gen-
    der. Sexual harassment, if committed or tolerated by the
    employer, becomes a new and onerous term of employment.
    
    [1] Sexual harassment falls into two major categories: hos-
    tile work environment and quid pro quo. See EEOC, Policy
    Guidance on Sexual Harassment, 8 BNA FEP Manual
    405:6681 (Mar. 19, 1990) (hereinafter EEOC Policy Guide).
    A hostile work environment claim involves a workplace
    atmosphere so discriminatory and abusive that it unreasonably
    interferes with the job performance of those harassed. A quid
    pro quo claim, as the name implies, occurs when a supervisor
    demands sexual favors in return for a job benefit. See gener-
    ally Barbara Lindemann & David D. Kadue, Sexual Harass-
    ment in Employment Law (1992). Additionally, employees
    who are subject to adverse employment actions because they
    lodged complaints of sexual harassment can raise a retaliation
    claim under Title VII. See id. at 275. Brooks alleges she suf-
    fered hostile work environment harassment during her
    encounter with Selvaggio, and retaliation by the city when she
    returned from the leave of absence precipitated by the inci-
    dent.
    
    Hostile Work Environment
    
    [2] In order to prevail on her hostile work environment
    claim, Brooks must show that her "workplace [was] perme-
    ated with discriminatory intimidation . . . that[was] suffi-
    ciently severe or pervasive to alter the conditions of [her]
    employment and create an abusive working environment."
    Harris , 510 U.S. at 21 (internal quotation marks and citations
    omitted). "The working environment must both subjectively
    
    13374
    
    and objectively be perceived as abusive." Fuller v. City of 
    Oakland , 47 F.3d 1522, 1527 (9th Cir. 1995) (citing Harris,
    510 U.S. at 21-22). We use a totality of the circumstances test
    to determine whether a plaintiff's allegations make out a col-
    orable claim of hostile work environment. See Harris, 510
    U.S. at 23. Harris lists frequency, severity and level of inter-
    ference with work performance among the factors particularly
    relevant to the inquiry. When assessing the objective portion
    of a plaintiff's claim, we assume the perspective of the rea-
    sonable victim. See Ellison v. Brady, 924 F.2d 872, 879 (9th
    Cir. 1991) ("[A] female plaintiff states a prima facie case of
    hostile environment sexual harassment when she alleges con-
    duct which a reasonable woman would consider sufficiently
    severe or pervasive to alter the conditions of employment and
    create an abusive working environment.") (footnotes and cita-
    tion omitted).
    
    Brooks claims the incident pervaded her work environment
    to such a degree that she required psychological help and even
    then was unable to successfully return to her job. She has
    alleged sufficient facts to support the subjective portion of her
    hostile work environment claim. The question remains
    whether her apprehension was objectively reasonable.
    [3] Because only the employer can change the terms and
    conditions of employment, an isolated incident of harassment
    by a co-worker will rarely (if ever) give rise to a reasonable
    fear that sexual harassment has become a permanent feature
    of the employment relationship. By hypothesis, the employer
    will have had no advance notice and therefore cannot have
    sanctioned the harassment beforehand. And, if the employer
    takes appropriate corrective action, it will not have ratified the
    conduct. In such circumstances, it becomes difficult to say
    that a reasonable victim would feel that the terms and condi-
    tions of her employment have changed as a result of the miscon-
    duct.4
    _________________________________________________________________
    4 A case involving a single incident of sexual harassment is obviously
    distinct from one involving a series of incidents, which the employer 
    
    13375
    
    Which is why Selvaggio's conduct, while relevant, is not
    the primary focus of our inquiry. No one could reasonably
    dispute that what Selvaggio did was egregious; he was, after
    all, immediately removed from his job and prosecuted. He
    spent time in jail. But it is the city, and not Selvaggio, who
    is the defendant here. To hold her employer liable for sexual
    harassment under Title VII, Brooks must show that she rea-
    sonably feared she would be subject to such misconduct in the
    future because the city encouraged or tolerated Selvaggio's
    harassment.
    
    [4] In support of her claim, Brooks points to Selvaggio's
    previous inappropriate advances toward female employees, in
    addition to her own encounter with him in the Communica-
    tions Center. However, Brooks cannot rely on Selvaggio's
    misconduct with other female employees because she did not
    know about it at the time of Selvaggio's attack. Harassment
    directed towards others of which an employee is unaware can,
    naturally, have no bearing on whether she reasonably consid-
    ered her working environment abusive. This is especially true
    where the harassment comes from an individual who is termi-
    nated as soon as his misdeeds come to light.
    
    Brooks next attempts to morph Selvaggio's single assault
    into a course of conduct by claiming that each of his improper
    touchings constituted a separate incident. While Selvaggio did
    touch Brooks inappropriately on her stomach and breast, this
    happened within the course of a few minutes and was part of
    a single episode. Additionally, Selvaggio had no chance to
    become bolder because the city removed him from the work-
    place once his actions were uncovered. No reasonable woman
    _________________________________________________________________
    knows about and does nothing to correct. In such circumstances, the non- 
    action by the employer can fairly be characterized as acquiescence, i.e., 
    having changed the terms and conditions of employment to include putting 
    up with harassment from other employees. See, e.g., Hostetler v. Quality
    Dining, Inc. , 218 F.3d 798, 802-05 (7th Cir. 2000).
    
    13376
    
    in Brooks's position would believe that Selvaggio's miscon-
    duct had permanently altered the terms or conditions of her
    employment.
    
    The single case Brooks cites to the contrary, Al-Dabbagh
    v. Greenpeace, Inc. , 873 F. Supp. 1105, 1111 (N.D. Ill. 1994),
    holds only that a plaintiff can demonstrate the subjective ele- 
    ment of a hostile work environment claim based on a single
    incident, even though she lacked knowledge of the offender's
    past misconduct. Al-Dabbagh did not rely on the perpetrator's
    past misconduct to establish an objectively hostile working
    environment, except to the extent the employer failed to disci-
    pline him for incidents of which it had knowledge. 5 Even
    were we to assume that the city's knowledge is relevant to
    establishing a hostile work environment, but see note 5 supra, 
    Selvaggio's conduct was not known to the city until after the
    _________________________________________________________________
    5 The objective portion of Al-Dabbagh's claim was based on the severity 
    of the incident plus negligence on the part of the employer, Greenpeace: 
    
    Al-Dabbagh alleges that Greenpeace had turned a blind eye to
    Mitchell's sexual abuse of female employees in its Chicago
    office before she fell victim to it and consequently suffered grave
    bodily and psychological injury. As already stated, Greenpeace's
    single response to Mitchell's earlier conduct--an oral reprimand
    for his drinking--fell far short of addressing the more serious
    problems posed by his conduct. There is no question that those
    allegations, credited as they must be on the present motion,
    amply support the first (objective) element of a hostile-
    environment claim--the evaluation of Mitchell's conduct by a
    reasonable person.
    
    Al-Dabbagh , 873 F. Supp. at 1111. It is unclear why past misconduct of
    which the complainant is unaware can contribute to a hostile work envi- 
    ronment simply because the employer is negligent in disciplining the
    employee who committed the misconduct. The lack of sufficient discipline 
    for an earlier and unknown act of misconduct does not, after all, make the 
    later misconduct more severe or pervasive with respect to the harassed 
    employee. Lack of adequate discipline might be a relevant consideration 
    in assessing the employer's liability once a hostile work environment is 
    shown to exist, but it seems to have no logical bearing on whether there 
    is a hostile work environment in the first place.
    
    13377
    
    assault.6 Brooks therefore can rely only on the single instance
    of sexual harassment directed toward her to support her hos-
    tile work environment claim.
    _________________________________________________________________
    6 Brooks claims that knowledge of Selvaggio's conduct can be imputed
    to the city because Pat P. knew of it (indeed was a victim) and was a 
    supervisor by virtue of her position as a senior dispatcher. Brooks relies 
    on Lamb v. Household Credit Servs., 956 F. Supp. 1511 (N.D. Cal. 1997), 
    for the proposition that an employer is deemed to know of harassment of 
    which a supervisor is aware.
    
    The city also relies on Lamb. It points to language indicating that super-
    visors, as that term is defined for Title VII purposes, are only those who 
    have authority to "hire, fire, or discipline employees, or recommend such 
    action." Id. at 1517. It is undisputed that senior dispatchers lacked the 
    authority to hire and fire dispatchers. While there is a vague reference to 
    senior dispatchers assisting with disciplinary measures, this is not suffi- 
    cient. See id. at 1517 (finding work flow supervisor with "limited set of 
    purely ministerial employee training and monitoring " functions not to be 
    a supervisor for Title VII purposes).
    
    Lamb also provides for imputation where an employee who has "gen-
    eral responsibility for passing employment-related complaints up the cor- 
    porate hierarchy" receives a complaint of harassment. See id. at 1516
    (citing Llewellyn v. Celanese Corp. , 693 F. Supp. 369, 380 (W.D.N.C.
    1988)). While senior dispatchers do have this responsibility, Lamb con- 
    fines the responsibility of these non-management employees. See id. at 
    1517: 
    
    [F]or purposes of Title VII, "management-level employees"
    encompass . . . non-management employees charged with sub-
    stantial responsibility for relaying employee complaints to man-
    agement, particularly where management is located away from
    the workplace. If a co-worker has knowledge of a harassee's
    complaint, but that co-worker lacks authority to counsel, investi-
    gate, suspend, or fire the accused harasser, or to change the con-
    ditions of the harassee's employment, the co-worker's inaction
    does not spark employer liability unless that co-worker has an
    official or strong de facto duty to act as a conduit to management
    for complaints about work conditions.
    
    Because Pat P., as a Senior Dispatcher, lacked power to change the condi- 
    tions of employment, did not serve as a conduit to off-site managers and 
    never actually received a formal complaint about Selvaggio, her knowl- 
    edge of his conduct cannot be imputed to the city.
    
    13378
    
    [5] We need not decide whether a single instance of sexual
    harassment can ever be sufficient to establish a hostile work
    environment.7 As we have previously held, "the required
    showing of severity or seriousness of the harassing conduct
    varies inversely with the pervasiveness or frequency of the
    conduct." Ellison, 924 F.2d at 878 (citing King v. Board of
    Regents , 898 F.2d 533, 537 (7th Cir.1990)). If a single inci-
    dent can ever suffice to support a hostile work environment
    claim, the incident must be extremely severe. See EEOC Pol-
    icy Guide, page 6 supra, at 405:6690-91 ("[A] single unusu-
    ally severe incident of harassment may be sufficient to
    constitute a Title VII violation; the more severe the harass-
    ment, the less need to show a repetitive series of incidents.
    This is particularly true when the harassment is physical."). In 
    Al-Dabbagh , a single incident was held to be sufficient where
    the assailant "slapped [plaintiff], tore off her shirt, beat her, 
    hit her on the head with a radio, choked her with a phone cord
    and ultimately forced her to have sex with him." Al-Dabbagh, 
    873 F. Supp. at 1108. The perpetrator held the victim captive
    overnight; when she finally managed to escape, she had to be
    hospitalized for her injuries. See id.
    
    [6] If the incident here were as severe as that in Al-
    Dabbagh , we would have to grapple with the difficult ques-
    tion whether a single incident can so permeate the workplace
    as to support a hostile work environment claim. Because the
    incident here was much less severe, we need not answer that
    question. Brooks did not allege that she sought or required
    hospitalization; indeed, she did not suffer any physical inju-
    ries at all. The brief encounter between Brooks and Selvaggio
    was highly offensive, but nothing like the ordeal suffered by
    _________________________________________________________________
    7 See Brown v. Hot, Sexy & Safer Prods., Inc., 68 F.3d 525, 541 n.13 
    (1st Cir. 1995) ("We do not hold that a one-time episode is per se incapa-
    ble of sustaining a hostile environment claim. The frequency of the alleged 
    harassment is a significant factor, but only one of many to be considered 
    in determining whether the conduct was sufficiently severe or pervasive 
    that a reasonable person would find that it had rendered the environment 
    hostile or abusive.") (internal quotation marks omitted).
    
    13379
    
    the unfortunate young woman in Al-Dabbagh, who was held
    captive from evening until early the next morning. Utilizing
    the Harris factors of frequency, severity and intensity of inter-
    ference with working conditions, we cannot say that a reason-
    able woman in Brooks's position would consider the terms
    and conditions of her employment altered by Selvaggio's
    actions.8 Brooks was harassed on a single occasion for a mat-
    ter of minutes in a way that did not impair her ability to do
    her job in the long-term, especially given that the city took
    prompt steps to remove Selvaggio from the workplace.
    Selvaggio's conduct is akin to that reported in cases where
    plaintiff was held not to have alleged harassment severe
    enough to support a hostile work environment claim. See, e.g., 
    Candelore v. Clark County Sanitation Dist. , 975 F.2d 588,
    590 (9th Cir. 1992) (per curiam) ("[I]solated incidents of sex-
    ual horseplay alleged by Candelore took place over a period
    of years and were not so egregious as to render Candelore's
    work environment `hostile.' ") (quoting Jordan v. Clark , 847
    F.2d 1368, 1374-75 (9th Cir. 1988)); Del Valle Fontanez v.
    Aponte , 660 F. Supp. 145, 146-47, 149 (D.P.R. 1987) (finding
    a single incident where defendant "pressed [plaintiff] against
    the door with his body" and plaintiff "felt defendant's erect 
    sexual organ against her body" twice in a five minute period
    not severe or pervasive enough to create a hostile working
    environment); see also Saxton v. American Tel. & Telegraph
    Co. , 10 F.3d 526, 528, 534 (7th Cir. 1993) (finding insuffi-
    cient harassment to constitute a hostile work environment
    
    _________________________________________________________________
    8 But see EEOC Policy Guide, page 6 supra, at 405:6691 ("The Com-
    mission will presume that the unwelcome, intentional touching of a charg- 
    ing party's intimate body areas is sufficiently offensive to alter the 
    conditions of her working environment and constitute a violation of Title 
    VII.") We are not convinced that such a presumption is consistent with the 
    Supreme Court's totality of the circumstances test approach in Harris. 
    Nevertheless, even were we to adopt this presumption, the brief duration 
    of the incident coupled with the city's effective remedial action would suf- 
    fice to rebut it.
    
    13380
    
    where plaintiff was rubbed and kissed on one occasion, and
    resisted an attempted groping on another).
    
    Ellison is not to the contrary. Ellison alleged a sustained
    campaign of harassing conduct directed at her. See Ellison,
    924 F.2d at 873-75 (recounting alleged harassment including
    love letters and date requests after plaintiff made it known
    that advances were unwelcome). Additionally, the course of
    conduct alleged by Ellison became more intense over time.
    Gray, the harasser, started by asking Ellison out a few times.
    He then sent her a brief love note followed by two letters. One
    of these comprised three single-spaced typed pages, and the
    other was sent after Gray had been told by his supervisors to
    cease his behavior. See id. Because Gray had continually
    ratcheted up the intensity of his advances, a reasonable
    woman could fear that this pattern would continue for as long
    as they were working in the same office. Nor did Ellison's
    employer effectively address Gray's behavior. After a brief
    transfer, Gray was again assigned to work with Ellison. Elli-
    son's working environment, characterized by a pattern of
    increasingly intense sexual advances from a co-worker and
    inadequate employer responses to her complaints, could cause
    a reasonable woman to believe that tolerating harassing
    behavior had become a term or condition of her employment.
    Our holding in no way condones Selvaggio's actions. Quite
    the opposite: The conduct of which Brooks complains was
    highly reprehensible. But, while Selvaggio clearly harassed
    Brooks as she tried to do her job, "not all workplace conduct
    that may be described as harassment affects a term, condition,
    or privilege of employment within the meaning of Title VII."
    Meritor Sav. Bank v. Vinson, 477 U.S. 57, 67 (1986) (internal
    quotation marks and citation omitted). The harassment here
    was an entirely isolated incident. It had no precursors, and it
    was never repeated. In no sense can it be said that the city
    imposed upon Brooks the onerous terms of employment for
    which Title VII offers a remedy.9See Faragher v. City of 
    
    _________________________________________________________________
    9 A different question would arise if Selvaggio were Brooks's supervi-
    sor, rather than her co-worker. Because the employer cloaks the supervisor 
    
    13381
    
    Boca Raton , 524 U.S. 775, 788 (1998) ("[T]hese standards for
    judging hostility are sufficiently demanding to ensure that
    Title VII does not become a `general civility code.' ") (quot-
    ing Oncale v. Sundowner Offshore Servs., Inc., 523 U.S. 75,
    80 (1998)). We therefore affirm the district court's grant of
    summary judgment with respect to Brooks's hostile work
    environment claims under Title VII and FEHA.10
    
    Retaliation 
    
    Six months after Selvaggio assaulted her, Brooks returned
    to work. While Selvaggio had resigned under threat of termi-
    nation, Brooks claims she returned to a very different work-
    place than the one she had left. Brooks initially noticed that
    her coworkers shunned her. Specifically, the males in the
    office refused to speak to her about anything other than work.
    She also saw pictures of Selvaggio in the Dispatch Center
    photo album, which were removed on her demand. Addition-
    ally, the city took its full 90 days to process Brooks's work-
    er's compensation claim. Later, she was required to attend
    group therapy sessions and discuss the incident in front of
    
    _________________________________________________________________
    
    with authority, we ordinarily attribute the supervisor's conduct directly to 
    the employer. See Burlington Indus., Inc. v. Ellerth, 524 U.S. 742, 765 
    (1998). Thus, a sexual assault by a supervisor, even on a single occasion, 
    may well be sufficiently severe so as to alter the conditions of employment 
    and give rise to a hostile work environment claim.
    
    10 Brooks also argues that the city is liable for its failure to take remedial 
    steps once it had knowledge, through Pat P., of Selvaggio's prior offend- 
    ing conduct. She relies on Fuller v. City of Oakland , 47 F.3d 1522 (9th
    Cir. 1995), to support her claim. But, as we have noted, senior dispatchers 
    are not supervisors whose knowledge can be imputed to the city. See note
    6 supra . In any case, Fuller does not establish a cause of action that is sep-
    arate from that for a hostile work environment or quid pro quo harassment. 
    It simply defines the liability of employers. "[I]f a hostile work environ-
    ment exists, an employer is only liable for failing to remedy harassment 
    of which it knows or should know." Id. at 1527 (quoting Ellison , 924 F.2d
    at 881). As there was no actionable sexual harassment, there is no liability 
    to assign to the city.
    
    13382
    
    coworkers. She had problems getting the shift she had when
    she took her leave of absence; was assigned to work with
    another dispatcher, Mike C., who had been close to Selvaggio
    and allegedly became openly hostile to Brooks; and had diffi-
    culty securing vacation time. According to Brooks, this treat-
    ment culminated in an unfavorable job evaluation.
    
    [7] We recently set out the peculiar dynamics of a retalia-
    tion claim under Title VII in Payne v. Norwest Corp., 113 
    F.3d 1079 (9th Cir. 1997). We noted that a plaintiff must
    show (1) involvement in a protected activity, (2) an adverse
    employment action and (3) a causal link between the two. See
    id. at 1080. Thereafter, the burden of production shifts to the
    employer to present legitimate reasons for the adverse
    employment action. Once the employer carries this burden,
    plaintiff must demonstrate a genuine issue of material fact as
    to whether the reason advanced by the employer was a pre-
    text. See id. Only then does the case proceed beyond the sum-
    mary judgment stage. We examine FEHA claims under the
    same burden-shifting structure. See Flait v. North Am. Watch 
    Corp. , 3 Cal. App. 4th 467, 476 (Cal. Ct. App. 1992).
    
    [8] Asserting one's civil rights, as Brooks did by complain-
    ing of Selvaggio's conduct, is a protected activity under Title
    VII and FEHA. See EEOC v. Crown Zellerbach Corp., 720
    F.2d 1008, 1013 (9th Cir. 1983); Blom v N.G.K. Spark Plugs 
    (USA), Inc. , 3 Cal. App. 4th 382, 388 (Cal. Ct. App. 1992).
    Brooks's complaint about Selvaggio's harassment thus satis-
    fies the first step of our inquiry.
    
    [9] The next question is whether Brooks alleged that she
    was subjected to an adverse employment action. In Strother
    v. University of S. Cal. Permanente Med. Group , 79 F.3d 859
    (9th Cir. 1996), we noted that "[n]ot every employment deci-
    sion amounts to an adverse employment action." Id. at 869. 
    We recognize the countervailing concerns in this area of the
    law. On the one hand, we worry that employers will be para-
    lyzed into inaction once an employee has lodged a complaint
    
    13383
    
    under Title VII, making such a complaint tantamount to a "get
    out of jail free" card for employees engaged in job miscon-
    duct. On the other hand, we are concerned about the chilling
    effect on employee complaints resulting from an employer's
    retaliatory actions. In an effort to strike the proper balance, we
    have held that only non-trivial employment actions that would
    deter reasonable employees from complaining about Title VII
    violations will constitute actionable retaliation. See Ray v.
    Henderson , 217 F.3d 1234, 1243 (9th Cir. 2000) ("[A]n
    action is cognizable as an adverse employment action if it is
    reasonably likely to deter employees from engaging in pro-
    tected activity."). Among those employment decisions that
    can constitute an adverse employment action are termination,
    dissemination of a negative employment reference, issuance
    of an undeserved negative performance review and refusal to
    consider for promotion. 11 By contrast, we have held that
    declining to hold a job open for an employee and badmouth-
    ing an employee outside the job reference context do not con-
    stitute adverse employment actions.12 With these principles in 
    mind, we examine Brooks's allegations of retaliatory treat-
    ment by the city. 
    
    [10] Because an employer cannot force employees to
    socialize with one another, ostracism suffered at the hands of
    coworkers cannot constitute an adverse employment action.
    See Strother , 79 F.3d at 869 ("[M]ere ostracism in the work-
    place is not enough to show an adverse employment deci-
    sion.") (citing Fisher v. San Pedro Peninsula Hosp., 214 Cal.
    App. 3d 590, 615 (Cal. Ct. App. 1989)). Indeed, holding an
    
    _________________________________________________________________
    11 See O'Day v. McDonnell Douglas Helicopter Co., 79 F.3d 756, 763
    (9th Cir. 1996) (termination); Hashimoto v. Dalton , 118 F.3d 671, 676
    (9th Cir. 1997) (negative reference); Yartzoff v. Thomas , 809 F.2d 1371,
    1376 (9th Cir. 1987) (negative performance reviews); Ruggles v. Califor-
    nia Polytechnic State Univ. , 797 F.2d 782, 786 (9th Cir. 1986) (refusing
    to consider for promotion).
    
    12 See McAlindin v. County of San Diego, 192 F.3d 1226, 1238-39 (9th
    Cir. 1999) (refusing to hold job open for employee); Nunez v. City of Los
    Angeles , 147 F.3d 867, 875 (9th Cir. 1998) (badmouthing).
    
    13384
    
    employer liable because its employees refuse to associate with
    each other might well be unconstitutional: "The First Amend-
    ment prevents the government, except in the most compelling
    circumstances, from wielding its power to interfere with its
    employees' freedom to believe and associate." DiRuzza v.
    County of Tehama , 206 F.3d 1304, 1308 (9th Cir. 2000)
    (quoting Rutan v. Republican Party of Ill., 497 U.S. 62, 76
    (1990)).
    
    [11] The group therapy sessions about which Brooks com-
    plains were workshops designed to better inform the city's
    workforce of its sexual harassment policy. Brooks does not
    claim she was singled out for the sessions, as all city employ-
    ees were required to participate in them. Her complaint seems
    to boil down to the non-private character of the sessions. But
    the employer has an interest in educating its employees about
    the adverse effects of misconduct that has occurred in the
    workplace. An employer's legitimate effort to deal with a
    traumatic workplace situation and educate its employees
    regarding sexual harassment cannot be the basis for a retalia-
    tion claim under Title VII.
    
    Next, we turn to Brooks's claims that she was scheduled
    with a co-worker, Mike C., who was openly hostile to her.
    While this might be an adverse employment action under cer-
    tain circumstances, the undisputed facts demonstrate that it
    was not here. Brooks was never scheduled to work with Mike
    C. He was sometimes on the dispatch floor when she worked,
    but Brooks has presented no evidence that the city put the two
    of them together knowing that Brooks would be uncomfort-
    able. Nor did Brooks present evidence that Mike C. was
    openly hostile, or hostile at all, toward her. She admits that he
    showed her no animus, nor did he express skepticism to her
    about her account as to what happened with Selvaggio. While
    it appears that Mike C. had been friendly with Selvaggio, a
    victim of sexual harassment is not entitled to avoid contact
    with the harasser's friends. So long as they show no outward
    
    13385
    
    signs of hostility, they are entitled to continue doing their jobs
    even though it brings them in contact with the victim.
    As for the fact that the city used all of its allotted 90 days
    to process the worker's compensation claim, Brooks offers no
    evidence that the city treated her differently from other
    employees seeking workers' compensation benefits. Absent a
    showing of disparate treatment, the city's delay cannot be
    deemed retaliatory. 
    
    [12] Brooks also alleges that her performance review was
    downgraded from "satisfactory" to "needs improvement" 
    because of her complaint about Selvaggio. We have previ-
    ously held that an undeserved negative performance review
    can constitute an adverse employment decision. See Yartzoff,
    809 F.2d at 1376 ("Transfers of job duties and undeserved
    performance ratings, if proven, would constitute`adverse
    employment decisions' cognizable under [Title VII].") (cita-
    tion omitted). Nevertheless, the evaluation here was not an
    adverse employment action because it was subject to modifi-
    cation by the city. Brooks refused to accept the review and
    appealed, but she abandoned her job while the appeal was
    pending. Because the evaluation could well have been
    changed on appeal, it was not sufficiently final to constitute
    an adverse employment action. Cf. Dobbs-Weinstein v. Van- 
    derbilt Univ. , 185 F.3d 542, 546 (6th Cir. 1999) ("Dobbs-
    Weinstein succeeded in the grievance process, and Vander-
    bilt's final decision was to grant her tenure. She has not here
    suffered a final or lasting adverse employment action suffi-
    cient to create a prima facie case of employment discrimina-
    tion under Title VII. To rule otherwise would be to encourage
    litigation before the employer has an opportunity to correct
    through internal grievance procedures any wrong it may have
    committed."). 
    
    Finally, Brooks claims that the city rescheduled her to an
    unfavorable shift and denied her vacation preference. How-
    ever, like the evaluation, these actions were not final. When
    
    13386
    
    Brooks complained, the city accommodated her preferences
    by allowing her to switch shifts and vacation dates with other
    employees.13 The district court did not err in rejecting
    Brooks's retaliation claim.
    
    III
    Brooks alludes briefly in her moving papers to a construc-
    tive discharge theory citing Turner v. Anheuser-Busch, Inc., 
    7 Cal. 4th 1238 (1994), and Watson v. Nationwide Ins., Co., 
    823 F.2d 360 (9th Cir. 1987). As explained in Turner, con-
    structive discharge occurs when the working conditions dete-
    riorate, as a result of discrimination, to the point that they
    become "sufficiently extraordinary and egregious to over-
    come the normal motivation of a competent, diligent, and rea-
    sonable employee to remain on the job to earn a livelihood
    and to serve his or her employer." Turner, 7 Cal. 4th at 1246; 
    see also Watson, 823 F.2d at 361 (noting that constructive dis-
    charge is found where a working environment is "so intolera-
    ble and discriminatory as to justify a reasonable employee's
    decision [to leave]"); EEOC Policy Guide, page 6 supra, at 
    405:6693 ("[A]n employer is liable for constructive discharge
    when it imposes intolerable working conditions [which] fore-
    seeably would compel a reasonable employee to quit .. . .").
    Brooks's complaints about her working conditions range
    from the trivial, such as issues with the pictures of Selvaggio
    in the dispatch center photo album, to the routine, such as
    scheduling conflicts. Taken collectively, these circumstances
    are not sufficiently extraordinary or egregious to amount to a
    constructive discharge. 
    
    _________________________________________________________________
    13 Brooks also alleges that, after she complained about Selvaggio, certain 
    police officers refused to provide her services that were routinely provided 
    to other dispatchers. However, the police did not employ Brooks and can- 
    not be held liable for retaliating against her. See City of Los Angeles Dept.
    of Water & Power v. Manhart, 435 U.S. 702, 718 n.33 (1978) ("Title VII 
    . . . primarily govern[s] relations between employees and their employer, 
    not between employees and third parties.").
    
    13387
    
    While Watson holds that the determination of whether
    working conditions are sufficiently egregious to support a
    constructive discharge theory is usually a jury question, see
    Watson , 823 F.2d at 361, the district court did not err in
    deciding that Brooks's claim fails as a matter of law. Taking
    the evidence in the light most favorable to Brooks, we cannot
    see how a reasonable trier of fact could find that she was
    driven from the workplace. Where a plaintiff fails to demon-
    strate the severe or pervasive harassment necessary to support
    a hostile work environment claim, it will be impossible for
    her to meet the higher standard of constructive discharge:
    conditions so intolerable that a reasonable person would leave
    the job. Cf. Thomas v. Douglas, 877 F.2d 1428, 1434 (9th Cir.
    1989) (constructive discharge requires some aggravating fac-
    tors, such as a continuous pattern of discriminatory treat-
    ment).
    
    AFFIRMED. 
    

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