Norinsberg Corp. v. Department of Agriculture

How later courts describe this case

• stating that after good-faith negotiations have exhausted the prospects of reaching agreement, an employer may make unilateral changes that are "reasonably comprehended within his pre-impasse proposals"
• noting that "mere utterance of an ... epithet which engenders offensive feelings in an employee" is not enough to constitute hostile environment harassment
• stating that after good-faith negotiations have exhausted the prospects of reaching agreement, an employer may make unilateral changes that are “reasonably comprehended within his pre-im-passe proposals”
• publication of office newsletter routinely ridiculing plaintiff due to her gender and her filing of EEOC charge alleging sexual discrimination found not to be adverse employment action
• “a breach of the duty of fair representation can constitute an unfair labor practice within the jurisdiction of the Board”
• Title VIPs prohibition against sexual harassment mandates equality not preference for women
• reversing jury finding of harassment