Brennan v. Townsend & O'Leary Enterprises, Inc

In Brennan v. Townsend & O'Leary Enterprises, Inc. (2011) 199 Cal.App.4th 1336, the trial court granted the employer's JNOV motion on the ground insufficient evidence supported a finding that the plaintiff had been subjected to severe or pervasive harassment based on her gender. (Brennan, supra, 199 Cal.App.4th at p. 1339.) The Brennan court rejected the plaintiff's claims of harassment partially because the evidence did "not show a concerted pattern of harassment of a repeated, routine, or generalized nature" or that the plaintiff found any of the actions offensive. (Id. at pp. 1355, 1357.) The court also concluded that the evidence did not show any retaliatory conduct based on the plaintiff's gender. (Id. at p. 1361.)