In Kovatch v. California Casualty Management Company (1998) 65 Cal.App.4th 1256, the Court decided whether the plaintiff could withstand summary judgment on a constructive discharge claim, and considered whether there was sufficient evidence for a trier of fact to find his working conditions were so intolerable that a reasonable person would have felt compelled to quit. (Kovatch, 65 Cal.App.4th at pp. 1267-1268.) Kovatch is not persuasive authority on a hostile work environment claim. The Court observed that Kovatch's supervisor "ostracized Kovatch, systematically took away his job responsibilities, and ultimately threatened Kovatch with termination." (Id. at p. 1270.)