In Accardi v. Superior Court (1993) at pages 352-353, the Court of Appeal explained that emotional distress caused by misconduct in employment relations (e.g., promotions, demotions, criticism of work practices, or grievance negotiations) may, regrettably, be considered to be a normal part of the employment environment. Thus, "a cause of action for such a claim is barred by the exclusive remedy provisions of the workers' compensation law. The Legislature, however, did not intend that an employer be allowed to raise the exclusivity rule for the purpose of deflecting a claim of discriminatory practices. Thus, a claim for emotional and psychological damage, arising out of employment, is not barred where the distress is engendered by an employer's illegal discriminatory practices." (Id. at p. 352, italics added; also see Leibert, supra, 32 Cal. App. 4th at pp. 1706-1707.) Similarly, in Kovatch v. California Casualty Management Co. (1998) Accordingly, where a plaintiff can allege that she suffered emotional distress because of a pattern of continuing violations that were discriminatory, her cause of action for infliction of emotional distress will not be barred by the exclusivity provisions of workers' compensation laws. This is so because the claim is "founded upon actions that are outside the normal part of the employment environment . . . ." (Accardi, supra, 17 Cal. App. 4th at p. 353.) Additionally, the same is true of harassment based on sexual orientation, where it has taken on the required degree of outrageousness. (Kovatch, supra, 65 Cal. App. 4th at p. 1278.)