The following excerpt is from Reynaga v. Roseburg Forest Prods., 847 F.3d 678 (9th Cir. 2017):
An employer is vicariously liable for a hostile work environment created by a supervisor. Vance v. Ball State Univ. , U.S. , 133 S.Ct. 2434, 2439, 186 L.Ed.2d 565 (2013). A supervisor is a person who can take tangible employment actions against an employee, including effecting "significant change in employment status, such as hiring, firing, failing to promote, reassignment with significantly different responsibilities, or a decision causing a significant change in benefits." Id. at 2443 (citation omitted).
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